IR 05000425/1988067
| ML20196A063 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/23/1988 |
| From: | Conlon T, Hunt M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20196A049 | List: |
| References | |
| 50-425-88-67, NUDOCS 8812050245 | |
| Download: ML20196A063 (12) | |
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O' 'k UNITED STATES
! E NUCLEAR REGULATORY COMM10SION
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\ ",,,, g' 101 MARIETTA ST ATLANTA. GE0fiGtA 30323 Report No.: 60-425/88-67 Licensee: Georgia Power Company P. 0. Box 1295
- Birmingham, AL 35201 Docket No.: 50-4 ?5 License No.: CPPR-109 Facility Name: Vogtle 2 Inspection Conducted: October 31 - November 3, 1988 Inspector: /&J M , d
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/l)2,NPg M. u. Hunt' vate signed
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Team Members: C. Paulk, Reactor Inspector Region II C. G. Bruch, Consultant RegionII(EG&GIdaho,Inc.)
Approved by & / h _/<,h r )7 l. t. Lonlon bection Uhlet
- X) //- 2 3~ W uate 51gned DivisionofkeactorSafety SUMMARY Scope: This special announced inspection was conducted in the areas of close 17/19 and 20 findings, CORs, out IFIs,ofURIs Readiness Review Modules and Violation ,12,ded was a review of the NRC's Also inclu electrical cable and equipment inspection program for completion for Vogtle Unit 2.
f Results: No violations or deviations were identified during this inspection.
i The licensee made every effort to cooperate and furnish the informa-tion necessary to closo the open items. The licensee management continues to 1maress on the personnel the need to perform all tasks properly and only once.
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REPORT DETAILS Persons Contacted Licensee Employees
- A. B. Callant, Project Compliance Coordinator
- E. D. Groover, QA Site Manager, Construction
- H. M. Handfinger, Project Startup Manager
- A. W. Harrelson, Construction Electrical Discipline Manager
- C. W. Hayes, Vogtle QA Manager
- R. E. Hollands, Electrical Coordination
- A. N. Lankford, Assistant Manager, QC
- D. C. McAffee, Senior QC Specialist
- R.W.McManus,AssistantProjectConstructionManager
- K. Pointer, Senior Plant Engineer
- R. J. Poper, Mechanical Field Office Staff Engineer
- J. E. Sanders, Assistant Project Manager Other licensee employees contacted during this inspection included craftsmen, engineers, operators, technicians, and administrative personne Other Organizations
- J. P. Hawley Project Engineer, Bechtel Power Coporation (BPC)
- R. C. Sommerfeld, Readiness Review - Mechanical, BPC
- P. R. Thomas, Readiness Review Team Leader, BPC
- S. K. Owen, Project Engineering Manager, Southern Company Services NRC Resident Inspector
- R. J. Scheppens
- Attended exit interview Action of Previous Inspection Findings (92701, 92702)
(Closed) VIO 50-425/88-07-01, Failure to Follow Procedure for High Potential Testing of Cable. During an NRC inspection conducted February 1-4, 1988, the failure to follow the procedure for high potential testing of cable was identified. The licensee concurred with the citation via letter dated April 14, 1988. The response was reviewed and determined to be acceptable. Discussions were held with responsible licensee representatives and supporting documentation was reviewed to verify that the corrective actions identified in the response have been ccmplete Reviews and evaluations were performed on all completed high potential test documentation packages. Three retests are reauired and were completed satisfactorily. Procedure 25733-C, High Potential Testing
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Cable, was revised to clarify the voltage level and time period reguired for testing. The revision ensured that the requirements were within the guidelines of industry standards and included the referenced standard Based on the above, this item is close (Closed)URI 50-425/88-07-02, Variation of Industry Standard Used for High Potential Test Procedure (Cable). During an NRC inspection conducted February 1-4, 1988, an apparent discrepancy was noted in Procedure 25733-C, High Potential Testing Cable. The revision in effect at the time did not reference the standards used to develop the procedures. Although not referenced, the procedure was in accordance with ICEA Publication No. 5-68-516, Ethylene-Propylene-Rubber Insulated Wire and Cable for Transmission and Distribution of Electrical Energy, and AEIC C 56-82, Specification for Ethylene Propylene Rubber Insulated Shielded Power Cables Rated 5 through 69KV. The procedure has been revised to clarify the length of time required for the test and to add the appropriate reference Based on the above, this item is close (URI) 425/88-26-01, Resolve the Items identified in Readiness Review Module 17/1 Three elements were identified. A description of each element and the basis for closure are as follows:
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Incom tion.plete The Verification of Safety licensee had Train installed Separation electric cables Criteria Applica-at numerous locations in the plant that did not provide the three feet horizontal and five feet vertical separation specified by Regulatory Guide 1.7 The original intent was to substitute Fire Scfety Barriers for spacing distance. Af ter noting the large number of firc safety barriers required, the licensee then engaged an independent laboratory to make specific tests in accordance with IEEE Standard 384 as allowed by RG 1.75. These tests provided the basis for
+1iminating of Fire Safety Barriers in many of the locations. The
.ot results, interpretation and complexity of application resulted in criteria for judging the acceptable field conditions for eliminating the requirement for Fire 'afety Barriers. The develop-ment of the criteria did not provide uniformity of presentation among different governing documents covering criteria, installation and inspection requirements. The licensee asserted that application of the various documents was both conservative and conformative on the basis that the most stringent requirements document was applied firs The most stringent document also was the earliest and did not completely implement the less stringent requirements of the later independent laboratory tests. Any deficiencies so disclosed by field inspection were to be checked using the newer criteria of the higher level documentation which incorporated the later independent laboratory tests. This review process conservatism and efficacy was not readily apparent due to the substantial differences of presenta-tion among the various documents. The licensee respense was the preparation of an extensive matrix which showed a case-by-case comparison of each field situation covered by the documentatio This verified that the review process was conservative and would
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result in unambiguous application of the reduced fire safety barriers requirements actually justified by the two laboratory test serie This element of URI 88-26-01 was close Thermal Separatio Field inspection by NRC inspectors disclosed one case where flexible conduit had been Installed in contact with a higher temperature regulating transforme Heat from the transformer was damaging the jacket at the point of contact and offering the possibility of overheating the conduct interior. Check of Procedure ED-T-02 failed to disclose a requirement for maintaining thermal separation between electrical raceways and higher temperature components other than piping. The licensee's response to this was the 3 reparation of a draft change to Procedure FP-4 (High Temperature and Equipment / Electrical Raceway Separation Finalization) for Unit This revision identifies higher temperature components throughout Unit 2, specifies separation criteria and requires a specific walkdown to check for inadequate thermal separatio This element of URI 88-26-01 is closed based on the expected licensee use of the draft procedure revisio Cable Tra Module 17y19Cover Installation. The NRC insoector's review of disclosed that the Readiness Rev.u Team did not assess total cable tray installation activities due to incomplete installation and the module publication cutoff dat The licensee's response to this was to perform a field verification of the tray cover installation activities at a later date using the originally developed Readiness Review Team check sheet NRC inspectors also inspected tray cover installations and did not find deficiencie This element of URI 88-26-01 0 closed based on the foregoin (Closed) URI 88-27-01 Resolve Items Identified in Readiness Review Module This URI contained four elements. A description of each element of the URI and the basis for closure is as follows:
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Nonspecified Color Codin Field inspection by the NRC inspector disclosed that certain installed components had a black identifica-tion label (indicating nonsafety related) along with a colored identification label (indicating safety related and the specific safety train). Discussion with GPC aersonnel indicated that this could be traced to procurement speci fications and was common in Unit 2. The licensee response was to set up an inspection for (1) those components (panels) listed in NRC Report 50-425/88-27 (2) Unit Diesel Generator Panels, and (3) Unit 2 Electrical Paneis requiring color coded labels. The purpose of the inspection will be to assure that the color of labels (or panels requiring color coded labels) is consistent and in conformance with applicable codes, specification, commitments, and criteria. This element of bRI 88-27-01 is closed based on the licensee's commitment to perform the inspection and to take such corrective action as is indicated thereb . l 7' !
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Inadequate Drip Loop Field inspection by NRC inspectors disclosed the lack of drip loop configuration for some cables entering cabinet 2-1805-53-888, a 480 V Motor Control Cente Absence of cable drip loops could increase water entry into the cabinet during operation of the fire sprinkler system. The licensee response to this was a walkdown of the Unit 2 Power Block which identified 468 items of equipment as requiring water protection. The lack of drip loops was to be addressed by closing the cable entry point with an appropriate sealant materiai rather than reforming the cable into a drip loo The requiremencs for the foregoing were entered into the project Master Tracking System as open items until such time as the moisture sealant has been applied. Work was complete on November 3 g 198 This element of URI 88-27-01 is closed based on the licensee s action to provide full correction of the deficiency and on NRC observation of the work while in proces Potential Junction Box Overheating. Field inspection by NRC inspectors noted the relatively hig,h operating temperatures of Sola Regulating Transformer The posribility, of convection currents carrying some of the transformer heat to junction boxes above the transformers, resulted in a concern that cabling terminating in these boxes could become overheated. The licensee conducted a specific investigation using a high-low indicatin junction box for a typical installation.g thermometer inside Data taken over ofhour a 25 the period disclosed that temperatures inside the junction box did not exceed the room (ambient) air temperature by more than 2.5 Transformer surface temperatures, during this same period, were never less than 34 F above ambient air temperature. The NRC inspectors reviewed the licensee's data and the transformer installation teste It was noted that the conduit surface temperature was very sensibly lower than transformer temperature one foot away from the transformers and close tc room temperature (tem]erature of nonheated components)atthejunctionbox. This confirmec data recorded by the licensee employe Also, the NRC inspectors reinspected the transformer installation referred to in NRC Report 50-425/88-27 which reported the basis for URI 88-27-0 The conduit surface temperatures were found to be near ambien The licensee was considered to have demonstrated adequately that no unsafe temperature condition existed and this URI element was close Inadequate Component Clearanc Field insaection by NRC inspectors disclosed the lack of minimum required c'earance (1-1/2 inches)
between cabinet 2-1806-03-DA1 and an adjacent cable tray support ar The licensee presented a calculation showing that the existing 1-1/4 inch clearance would be degraded by 0.04 inches during an Operating Jasis Earthquake (0BE). The calculation was reviewed by the NRC inspettors and considered to be adequate. This URI element was closed based on the results of this calculatio (Closed) URI 88-27-02, Incorporate Protective Relaying Design into the FSA Review by NRC inspectors disclosed that FSAR Section 1.4.5.3 made a
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general design responsibility assignment to the Bechtel Power Compan The design of protective relaying, however, was found as being performed by the Georgia Power Company Protection Engineering Group who wer not part of eitner Bechtel or the Vogtle projec The licensee response to this anomaly was to initiate a FSAR change to clearly assign this work to the Protection Engineering Group and the audit responsibility to the Vogtle Quality Assurance Manager until such time as the plant is accepted for operation. This FSAR change maintains the licensee practice of having a single technical group accomplish protection design for all licensee lants but provides overview by the Vogtle project through the means of Udlity Assurance audits. This URI is closed based on the wording of a raf t FSAR change currently undergoing licensee review and will to be part of FSAR Amendment 39 to be released later this calendar year (1988). This FSAR change is considered to provide adequate Vogtle project control of the GPC Protection Engineering Group's design of protection relaying at VEG (Closed)URI 425/88-40-01, Damage to Cable During Installation of Stainless
$ teel Tie Wrap The insisctor reviewed an engineering report which evaludted the use of stainless steel tie wraps to support cables in long vertical cable trays. This evaluation explored the aspects of a cable construction, weight / force margins, angles of incidence of the cable tie, cable aging, and industry studies and experiences. Based on this report it was concluded that the stainless steel tie wraps will not cause unacceptable deterioration of the cables over the forty year life of the plant. The two manufacturers of the cables used in the mos". Class 1E applications that presented the most likely and possible damaging situa-tions vertically installed cable runs were contacted and g,1ven the engineering evaluation. Both vendors concurred that the stainless steel tie wraps would not damage or compromise the integrity of their cable An employee concern had also been submitted to the Quality Concerns Unit expressing the same concern as this URI. The inspector reviewed the response to the concerned employee and noted that the individual had accepted the response and had no further concerns. This item is close (Closed) Violation 425/88-48-01, Failure to Properly Tighten Flexible Ccnduits in Containmen The licensee's actions to correct the condition cited was verified by the inspecto A walkdown of the areas which contain the conduits in question was made by the inspector to verify that the conduit fittings were now tight and that compliance was achieved as of November 3, 1988. This item is close (Closed) URI 88-48-02, Resolve Items identified in Readiness Review Module 1 A description of the separate elements of the URI and basis for closure are as follows:
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Penetration Loading Calculation The licensee reported in Module 12 that module publication deadline had not permitted review of the electrical penetration assemblies (EPA) loading calculations by the Readiness Review Tea Credit had been taken for the review of
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program controls made during the Module 6 review of Unit The NRC inspectors' examinations of that review did not support the credit taken since it did not show specific review of the EPA loadino ~
calculations for Unit 1. The licensee response to this URI was to select three Unit 2 penetrations and to perform the originally planned review of the calculations for these thre The NRC Inspectors examined the Readiness Review Team check sheets and the actual calculations related thereto. No verification errors were found during this examination. This element of URI 88-48-02 was close Cable Tray Edge Protectio Field walkdowns by the NRC ins]ectors disclosed several cases where cables were in contact with ca)le tray edges without the benefit of edge protectors as had been installed at numerous other cable transition locations. The licensee response was to correct the five locations reported in NRC Report 50-425/88-4 The licensee inspected other trays in the general area and found the similar problems which were corrected. A further licensee inspection at areas (rooms) released to the Operations Department disc'osed additional instances of inadequate edge protection. This has resulted in the modification of Exhibit 01 (Facility Walkdown Electrical Checklist) of Procedure E0-T-33 [ Electrical Facility (AREA)CompletionandTurnover]. The licensee use of this procedure is expected to embrace all safety related areas and components of Unit 2 and thus will provide a final assurance of adequate edge protectio This element of URI 98-48-02 was closed based on the licensee's use of the modified checklist for Area turn-over of Unit Controls Cable Ampacity Derating. The NRC inspector review of
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licensee FSAR commitments for hodule 12 disclosed that Desi Criteria DC-1809 (Cable System) did not recuire cable ampac1'gnty derating analysis for power tray fills exceed ng 30% or control cable fills exceeding 40% This analysis was required by FSAR Section 8.3.1.4.2 (Cable System). The licensee offered evidence (1) based on the ICEA 46-426 application of temperature provision of the National Electric Code, (2) on thn basis of minimum wire sizes used for control cables, and (3) on current limitations of control circuit This showed that control cabies would always be within normal industry temperature limitations and thus derating would not be require The licensee showed that the EE-580 (Cable and Raceway Tracking and Control System) always flagged power cable fills exceedino 40L These were checked for derating requirements by PFE-X30106 Desk Instruction The foregoin evidence that the intent of FSAR Section 8.3.g1. of fered hadacceptable been carried out for power trays. The URI was written to recognize the anomaly that existeu between the FSAR and the actual practice. The licensee response was to draf t a change to DC-1809 to address the FSAR requirements by (1) requiring power cable trays having fills greater than 30% to be analyzed for ampacity derating and (2) referring to calculation X3CK03B for control cables where tray fills exceed 40%
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(calculation demonstrating that ampacity derating is not required since control cables are never less than 12 or 14 A.W.G. and never carry more than 10 Amperes). This element of URI 88-48-02 was closed based on the expected prompt issue of DMCN DC-1809-1 (Closed) Violation 425/88-49-01, Failure to Protect Installed Equipmen The inspector verified that the licensee had taken the corrective actions required as committed to in their response to this violation. The area turnover process had been reviewed to insure that adequate inspection of installed instrtmentation components is accomplished and items needing repair are identified. The licensee appeared to be in compliance as of November 3, 1988. This item is close (Closed) URI 50-425/88-49-02, Resolve Items Identifieo in Readiness Review Module 20. During an NRC Vogtle Readiness Review Team inspection a discreaancy was noted concerning color coding and tagging in,struments ay construction. Procedure X4AZ01, Div. P2, Rev. 19, Instrumentation Installation Construction Specification required color coding and tagging of instruments and sensing line Contrary to this requirement, several instruments were identified in the previous report as not meeting the requirements of X4AZ01 Div P The licensee stated that +he markings required were for the
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construction phase only, and were not required to be maintained after acceptance by Nuclear Operations. All instruments identified had previously been accepted by Nuclear Operations and were not under the jurisdictional control of constructio In order to alleviate any further concerns X4AZ01 Div P2 was revised on October 19, 1988. The revision addresses the purpose of the construction markings as construction aids for insuring that pr,oper trair separatior is verified, the need to maintain the markings is no longer necessary. Based on the above, this items is close . Electric Cable - Work Observation and Record Review (51063, 51065)
The licensee has recently completed a Readiness Review Module No 17/19, Electrical Raceways and Su3 ports. The module results were examined and accepted under Inspection Report 50-425/88-26 issued on August 24, 198 The module assessment using an approved check list which incorporated all the inspection attributes of Field Procedure ED-T-02-Raceway Installation verified the following numbers of hardware and documentatio Item Quantity Trays 39 Locations Conduits 25 each Raceway Documentation 64 sets Tray supports and Documentation 16 each Conduit Supports and Documentation 25 each
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Additionally, an NRC independent sample verification was performed for 14 individual raceways and associated supports. This task involved a broad range of hardware types in Class I location The independent verification included the following attributes:
Design Conformance Support Location Identification Marking Bolt Torque Welding (if not concealed by subsequent painting)
Se)aration Criteria Caale T.ay Cleanliness Cable Tray to Cable Program Correlation Tray Cover Installation Deviation Report Documentation ( QC Inspection The sample listed in Table 2 of Inspection Report 50-425/88-26 includes l both conduit and cable trays for power, control and instrumentation '
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cable l The licensee's receipt and inspection activities were reviewed at various
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times during the NRC inspection progra . Electrical Components and Systems - Work Observation and Records Review l (51053) (51055) l l
During the NRC review of Readiness Review Module # 6 the following items were selected for record and walkdown verification. In certain instances followup walkdowns of the licensee's verification and walkdowns of items included in the module report were performed These items are identified below:
Equi )men RRT NRC TAC iumber Description Sample Sample 2-1804 53-A03 Med voltage SWCR 2BB03 *
2-1805-53-8B8 480 V MCC 2BBB * *
2-1806-B3-BYA 125 V dc battery *
2-1806-83-CBB Battery charger *
2-1806-83-BYB 125 V dc battery and rack 2801B *
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125 V dc dist, panel * *
2-1806-Q3-DA1 2-1806-53-DA1 125 V de dist. panel *
2-1806-53-DSB 125 V dc switch gear *
125 V de dist, panel *
2-1807-Q3-VII
2-1807-Q3-V16 125 V de dist. panel l
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Equi > ment RRT NRC TAC iumber Description Sample Sample (cont'd)
2-1807-Y3-IB12 Inverter *
2-1807-Y3-RX7 Regulating transformer *
2-1808-T3-106 Regulating transformer *
2-1816-U3-007 Elect, aux. board *
2-1818-H3-P13 H.V. penetration * *
2-1818-H3-P29 480 V penetration *
2 ~821-H3-P50 Control penetration *
2-1818-H3-P71 Instrumentation penetration *
2-1821-03-001 Safety feat, seq. board irn. * *
2-1825-53-BAB 13.8 KV RCP SWGR 2-1801-QS-MCG Main entl. board Sect. A01 *
2-1601-03-T27 Termination cabinent *
Solid state protected system *
2-1605-QS-SPA 5. Licensee Identified Items - 10 CFR 50.55(e), Construction Deficiency Reports (CDR)
(Closed) CDR-84-59, Transamerica Delaval D/G Thrust Bearing Luhricatio This item was reported to the NRC on March 23, 1984, and tbs final report was submitted on November 12, 1984. The problem was proper lubrication of the turbo charger thrust bearing during a quick start after a long standby period. The modifications were unique for each TDI D/G and required testing to determine the corrective actions required. Close out action approval by Q/C for the Unit 2 D/Gs was dated March 1,1988, for D/G 2A and July 21, 1988, for D/G 28. This items is close (Closed) CDR 85-98 - Transamerica Delaval Diesel Generator cylinder Head Weld Repair - This item was reported to the NRC on December 4,1985. The final report was submitted on January 23, 1986. At that time the licensee committed to return any Unit 2 diesel generator cylinder heads that had been repaired using the questionable weld repair procedure to the vendo The cylinder heads for both Unit 2 diesel generator engines were inspected and the following cylinder heads wer identified as unacceptable and were returned to the vendor and replaced:
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Diesel Generator 2A Cylinder head ID
- 2 Left Bank
- 8 Left Bank
- 1 Ri ht Bant
- 4 Ri ht Bank
- 8 Right Bank Diesel Generator 28 Cylinder Head 10
- 2 Left Bank
- 2 Right Bank The diesel generators have been reassembled and operational testing is in progress. This item is closed.
(Closed) CDR-86-123, Diesel Generators (0/G) Control Panels Relay. This item was reported to the NRC on August 6,1986. The final response was submitted on November 20, 1986. General Electric Company relays were wired in reverse polarity by the diesel generator engine control panel fabricator causing burnout of some relays in Unit 1 0/G panels.
Corrective actions were taken which modified the existing wiring in the engiie control panels for the Unit 2 D/Gs and replacement of the under frequency relay. A review of QC inspection records indicated that the work was testing satisfactorily accomplished by completed en March 29,is preop Test 2-BKJ-0 Th item is closed.1986, and operationa (Closed) CDR 87-140, Electrical Cable Separation Within Panels. The licensee submitted what they considered their final report on February 24, 1988, concerning electrical cable separation within panels. The report was reviewed and determined to be acceptable. Discussions were held with responsible licensee representatives and supporting documentation was reviewed to verify that the evaluations, reviews, and corrective actions have been co:plete Additional testing was perforn.1d by Wyle Laboratory and evaluations were oerformed that indicate the instances where separations criteria did not meet the requirements of RG 1.75 were acceptable. Changes have been made to the FSAR tc reflect the results of Wyle Test Reports 48141-02 and 17959-02 and to incorporate the changes that resulted from their findings. These changes were submitted to the NRC by letter dated March 14, 1988. Based on the above, this item is closed.
(Closed) CDR 88-142, Electrical Cable Tray Separatio The licensee submitted what they considered their final report on May 10, 1988, concerning cable tray separation and lack of cable tray covers. The report was reviewed and determined to be acceptabl Discussions were held with responsible licensee representatives and supporting documentation was reviewed to verify that the evaluations, reviews, and
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corrective actions have been completed or are being tracked to ensure c ompl etio The evaluations and reviews were included with those
' performed to resolve CDR 87-140 (discussed above) and corrective acti are being implemented to resolve any discrepancies identified. Completion of the corrective ection items is being tracked via FSBRs and MTS. Based on the above, this item is close . Exit Interview The inspection scope and results were summarized on November 3,1988, with those persons indicated in paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results listed abov Although reviewed during this inspection, proprietary information is not contained in this repor _