IR 05000456/1985028
| ML20137F657 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 08/22/1985 |
| From: | Falevits Z, Love R, Mendez R, Muffett J, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20137F643 | List: |
| References | |
| 50-456-85-28, 50-457-85-28, NUDOCS 8508270043 | |
| Download: ML20137F657 (11) | |
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U.S. NUCLEAR REGULATORY COMISSION
REGION III
Report Nos. 50-456/85028(DRS); 50-457/85028(DRS)
Docket Nos. 50-456; 50-457 License Nos. CPPR-132; CPPR-133 Licensee:
Commonwealth Edison Company Post Office Box 767
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Chicago, Illinois 60690 Facility Name:
Braidwood Station, Units 1 & 2 Inspection At:
Braidwood Site, Braidwood, Illinois Inspection Conducted:
May 21-23, June 4-7, June 14 and August 14, 1985
/kI Inspectors:
M
- $. Y Z. Falevits 2 #5 Date SS/;r.//t[
R. S. Love Date
/J19
's I V J. Muffett f
I Date Approved By:
C. C. Williams, Chief Y A.//1r[
Plant System Section Date
Inspection Summary Inspection on May 21 through August 14, 1985 (Report No. 50-456/85028(DRS);
50-457/85028(DRS))
Areas Inspected:
Routine, unannounced inspection of licensee action on previous inspection findings; 50.55(e) reports; an allegation; electrical separation; cable pulls; control room chillers; manual trip circuit; and inspection of electrical activities.
This inspection involved a total of 106 inspector-hours by 4 NRC inspectors including 22 inspector-hours during off-shifts.
Results: Of the areas inspected, no violations or deviations were identified.
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n508270043 850823 PDR ADOCK 05000456 G
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DETAILS 1.
Persons Contacted Commonwealth Edison Company (CECO)
+C. W. Schroeder, Project Licensing and Compliance Superintendent
- A. D. Miusi, Nuclear Licensing Administrator
- C. A.'Mennecke, Project Construction Department - Lead Electrical
- J. J. Dennehy, PED Engineer
+J. W. Geiseker, PCD Electrical Engineer
+J. F. Phelan, Project Field Engineer
- D. A. Hoffer, Quality Assurance Engineer
- E. R. Netzel, QA Supervisor
- L. M. Kline, PLC Supervisor
- W. E. Vahle, Project Fie'id Engineer
- M. Teras, Project Field Engineer
- D. L. Cecchett, Licensing Engineer
- P. L. Barnes, Licensing Engineer
- G. Kern, Project Licensing and Compliance Engineer
- N. Tomis, Project Operation Analysis Supervisor
- J. Frizzell, SNED Engineer Sargent and Lundy (S&L)
- J. D. Regan, Electrical Project Engineer
- T. B. Thorsell, Senior Electrical Project Engineer
- B. G. Treece, Senior Electrical Project Engineer
- S. Eldridge, Structural Engineer
- P. Olsen, Engineering Analyst
- R. Larson, Engineering Analyst
- R. Jason, Project Engineer
++M. Ulloa, Electrical Engineer
++D. Galanis, Electrical Project Engineer
++T. Eisenbart, Electrical Project Engineer L. K. Comstock Company (LKC)
- I. F. Dewald, QC Manager
- R. Seltman, QA Manager U. S. Nuclear Regulatory Commission (NRC)
- J. A. Stevens, Licensing Project Manager, NRR
- S. C. Rhow, Electrical Reviewer, NRR
- W. S. Little, Branch Chief, Region III
- R. S. Love, Reactor Inspector, Region III
- M. J. Farber, Reactor Inspector, Region III
- L. S. McGregor, Senior Resident Inspector, Region III
- S. Stein, CAT Electrical Inspector
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- Denotes those personnel attending the May 23, 1985, exit interview at the S&L office.
- Denotes those personnel attending the June 7, 1985, exit interview.
+ Denotes those personnel attending both the May 23, 1985 and June 7, 1985, exit interview.
- Denotes those personnel attending the June 14, 1985, exit interview.
++ Denotes those personnel attending the August 14, 1985, exit interview.
2.
Action on Previously Identified Items a.
(Closed) Open Item (456/84-23-01; 457/84-22-01):
It was previously identified that the minimum bend radius was violated during an inprocess pull of cables 1AP073-P1E and 1AP320-P1E.
Sargent and Lundy drawing 1-3000B required that the minimum bend radius be 19\\"
for 1/C - 750 mcm cable.
The measured bend radius for one of the cables was determined to be 14 3/4".
A nonconformance report, NCR 644, was issued to resolve this item.
This NCR was dispositioned
"Use-As-Is" by Sargent and Lundy on October 1, 1984.
This acceptance was based on the manufacturer's (0konite) instruction that the conditions encountered during the cable pull were temporary training with no pull tension applied.
b.
(0 pen) Open Item (456/84-23-03):
During a review of terminations in junction box IJB428R-K1R, the inspector observed that three copper conductors were not fully inserted into the lugs.
Another termination was observed with the conductor extending beyond the barrel of the lug.
The concern is whether these terminations are mechanically and electrically acceptable.
The licensee was requested to reinspect these terminations and determine their acceptability.
Subsequent to the identification of the above concerns, Comstock issued a Inspection Correction Report, ICR 7519.
This ICR identified cable IRC 723 (K1R) on terminal block TB1, point 3, as not being properly crimped.
Corrective action was accomplished and the ICR report was closed out.
However, due to time constraints rework of the terminations were not physically examined by the inspector.
Pending further review of the subject terminations, and other terminations of this type, this item remains open.
c.
(Closed) Open Item (456/84-29-01):
It was previously identified that the 4160/480 ESF Transformer 131X-1AP11E was not labeled with a Division I or Division II equipment identification code.
This transformer had been identified with a grey piece of tape.
On April 29, 1985, the nameplate on the transformer panel 1AP11E was installed by Project Operational Analysis personnel.
The inspector visually examined the as-installed nameplate and found it to be correct.
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3.
Action on 10 CFR 50.55(e) Reports a.
(0 pen) 10 CFR 50.55(e) (456/83-12-EE; 457/83-12-EE):
" Failure of Anaconda Flexible Conduit Jacket." During hot functional testing at Byron Station the jacket of Anaconda type NWC flexible conduit used inside the containment was discovered to be split open.
On September 9, 1983, the licensee committed to have all liquid tight flexible conduit jackets covered with Okonite T-35 jacket tape.
This jacket tape is also used on Okonite cable terminations and is qualified for the containment environment.
On April 18, 1985, in a revised final report, the licensee stated that all Anaconda type NWC and NPW would be replaced with stainless steel flexible conduit or modified by one of two taping procedures described on the electrical installation drawings.
The licensee is approximately 50 percent complete in repairing or reworking the flexible conduit in the Unit 1 containment.
This item remains open pending final review and inspection by Region III.
b.
(0 pen) 10 CFR 50.55(e) (456/84-13-EE; 457/84-13-EE):
" Electrical Butt Splices." On August 1, 1984, the licensee notified the Region of a potential deficiency regarding electrical butt splices which were not installed in accordance with the manufacturer's recommendations.
The licensee determined that L. K. Comstock's procedures did not include the manufacturer's installation instructions or inspection criteria for conductor extension butt splices.
Subsequently, the licensee's site QA department inspected 29 safety-related splices and rejected 11 (38%) of the total sample.
The licensee's corrective action was to develop an inspection program to verify that the installed splices were in conformance with criteria established in the attachment to Braidwood nonconformance report NCR 598.
The licensee has committed to identifying and inspecting all safety-related butt splices except those terminated after the installation and inspection procedure upgrade that occurred on May 1, 1984.
Deficient splices would be repaired and reinspected in accordance with the revised procedures.
During this reporting period, the licensee's field inspections had been initiated and the inspection results were not available.
This item remains open pending further evaluation by the inspector.
c.
(0 pen) 10 CFR 50.55(e) (456/85001-EE; 457/85001-EE):
" Failure of Westinghouse Circuit Breakers to Meet Required Ratings." The licensee determined that the 480 volt, 10 amp circuit breakers did not meet S&L Specification F/L 2755.
The breakers had an interrupting rating of 4,000 to 5,000 amps.
The rating should have been equal to or above the 14,000 ampere fault current capability of the 480 volt MCC bus.
On January 10,1985, the licensee issued a nonconformance report which required that all Westinghouse 10 amp thermal magnetic 480V breakers be replaced with 15 amp thermal magnetic breakers which are to be supplied by Westinghouse.
This item remains open pending final review and inspection by Region III.
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4.
Followup on Allegation Allegation (ATS No. RIII-84-A-0182)
As part of an allegation received December 17, 1984, the alleger advised the NRC that he had a concern with pipe support M-1RC110975 at Braidwood.
The alleger also produced a hanger drawing of support M-IRC110975.
The alleger stated that there was no clamping force produced on the valve being supported and also that the support was unstable in compression.
NRC Review The hanger drawing produced by the alleger was a design sketch which had none of the required signatures and this design sketch had not been released for construction.
The NRC inspector acquired the final design drawing of hanger M-IRC110975 which contained all required signatures and approval and had been released for construction.
The final design incorporated changes which provided clamping force and the final design was not unstable in compression.
In addition, the NRC inspector inspected pipe support M-IRC110975 and found the support to be as specified on the final design drawing.
Conclusion This allegation is unsubstantiated.
Pipe support M-1RC110975 was redesigned as part of the A-E's normal design process addressing the areas of the alleger's concerns.
5.
NRR Review of Electrical Separation On May 21-23, 1985, a Region III inspector met with the NRR Electrical Reviewer and CAT Electrical Inspector at the Braidwood Nuclear Power Station to review the acceptability of the electrical separation criteria for the Byron /Braidwood Stations.
During a tour of the plant, the NRR Electrical Reviewer was shown various examples of separation violations to the requirements of IEEE-384-1974,
" Trial-Use Standard Criteria for Separation of Class 1E Equipment and Circuits," and Regulatory Guide 1.75, Revision 2, " Physical Independence of Electrical Systems." The violations identified were between safety-related and nonsafety-related cable trays, conduits, cable trays and conduits, cables in free air, and cables in tray with cables in free air.
The Byron /Braidwood FSAR takes exceptions to IEEE-384 and Regulatory Guide 1.75.
A review of the FSAR, Paragraph 8.3.1.4.2, Physical Separation Criteria indicates that Tray Separation Criteria was last revised by Amendment 38 (May 1982) and Conduit Separation Criteria was last revised by Amendment 39 (September 1982).
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During the Exit Interview, the licensee was requested by NRR to provide the " worst case" analysis for various installations, i.e., tray to tray, cable to cable, conduit to conduit, etc.
NRR is reviewing these analyses, and will issue an amendment to t5e Byron and Braidwood SERs regarding the status of separation criteria as stated in the FSAR.
The NRR Licensing Project Manager reminded the licensee that regardless of the outcome of the review, the licensee would not be relieved of their commitment to Region III to complete:
A 100% walkdown of all safety-related buildings and identify a.
electrical separation violations.
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Rework the adverse item (s) to correct the violations, or c.
Install approved barriers, or d.
Perform an analysis to demonstrate that the separation violation can be accepted as installed.
The licensee (Mr. C. W. Schroeder) stated that Ceco would honor their commitments to Region III and would respond to the NRR request for analysis of the worst case conditions and appropriate changes to the FSAR.
6.
Functional Areas Inspected a.
Observation of Cable Pulls
.(1) The inspectors observed cable pulling activities performed during offshift hours.
The following cable pulls associated with the Aux Building Vent Stack Wide Range Gas Monitoring system were observed.
Thru Cable Cable Tray From To Conduit IPR 331 l IPR #16 shielded l IRT-PR030 l 1RY-PR0308 l C0A8910 1PR332 l l
l l C0A8910
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1PR334 l l
l 1RY-PR030A l C0A8910 1PR335 l l
l l C0A8910
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1PR350 l l
l 1RY-PR030C l C0A8910 &
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l l C0A8929 1PR351 l l
l l C0A8910 &
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l l C0A8929 IPR 357 l 1/C #10 l
l l C0A8910 &
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l l C0A8929 1PR356 l 1/C #10 l 1RY-PR030C l 1RY-PR030A l C0A8929 1PR333 l 1PR #16 shielded l l
l C0A8929
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The inspectors observed that both IPR #16 shielded and 1/C #10 cables had been pulled through conduits C0A8910 and C0A8929.
A review of design drawings 6E-0-4708E, Revision C, 6E-0-4705A, Revision J, and 6E-0-0430PR18, Revision A, indicated that the licensee had utilized IPR #16 shielded cables for 120V AC feed
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to RM-80 (1RT-PR030) unit, as well as for the 4-20 m.a. stack flow input and 0-5V stack flow output signals.
The 1/C #10 cable was utilized for the ground input of the 120V AC feed to the RM-80 unit.
As a result of these observations, the inspectors requested the licensee address the following concerns:
(a) Are the 1PR #16 shielded cables adequately sized and selected to N carry the 120V AC feed to the RM-80 units?
(b)
Is it appropriate to route instrumentation cables (IPR #16) and control cables (1/C #10) carrying instrument signals and control power signals in the same conduits?
(c) A conflict exists between drawing 6E-0-4030PR18, Revision A, and drawing 6E-0-4708E, Revision C, pertaining to the grounding and shielding portion of the circuit in that first drawing shows all terminations done at TB1-12 while second drawing indicates ground terminations at points 9 and 12 including an additional jumper between the two points.
FSAR, Paragraph 8.3.1.4.1.2 defines control cables as cables which supply electrical energy from distribution panels to 120V AC and 125V DC instrumentation, control and alarm circuits.
The FSAR further states, " Generally all 600V-(insulation class) cables feeding 120V AC or 120V DC circuits sized with #14 or #10 conductors, are considered control cables... Instrumentation cables are defined as those cables conducting low-level instrumentation and control signals... Typically, those cables carrying signals of less than 50 m.a... Generally, instrumentation cables are one of the following types:
- 16, #20 shielded pairs, coaxial or triaxial." At the conclusion of the inspection (Exit Interview), the licensee indicated that the current level of the 120V AC feed appears to be low and is therefore not a problem in their opinion.
Pending further review, this item is considered open (456/85028-01; 457/85028-01).
(2) During this inspection the inspectors noted various instances where three lugs have been placed on a single terminal of control relays in Process Radiation Unit 1RT-PR030 and in Diesel Generator Panel 1PLO7J (1ADG) resulting in reduced bolt engagement.
CECO wiring standard C-2325 item IV-12 does not permit more than two lugs on one termination point. The
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inspector requested the licensee review the QA program and I
specification requirements regarding the number of lugs allowed on a single terminal.
At the conclusion of the inspection, the
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licensee indicated that no specific requirement could be found limiting the number of lugs terminated by the various vendors on internal components inside a panel.
Pending further review this item is considered open (456/85028-02; 457/85028-02).
b.
Review of Licensee Action on Control Room Chillers (1) The inspectors and the licensee discussed deficiencies associated with the control room chiller system identified during startup testing of the control logic.
On May 2, 1985, startup testing found that on remote starting, the safety circuit relays in control room chiller OW001CA and control panel OW001CA-C chattered due to a low voltage condition.
This condition was also identified on Division B chiller 0W001CB.
Subsequently, Deficiency Reports WO-10-119 for Division A and WO-10-118 for Division B, were issued to document the excessive voltage drop condition.
Startup test engineering had measured 70V AC at the relays instead of the nominal 120V AC. The licensee determined that due to the circuit length, conductor size and load, excessive voltage drop was occurring at the local control relay panel.
Field Change Request (FCR) L-18472 was issued to initiate action to make minor schematic and wiring changes and to use existing spare conductors to reduce the voltage drop.
The proposed corrective action resulted in d ubling the conductors to the terminations in the control room cLiller circuitry and documenting the changes on the applicable connection and schematic diagrams.
The inspectors reviewed applicable connection and schematic diagrams of the chiller systems.
The inspectors determined that only some of the termination to termination points in the chiller circuit were connected with an extra conductor of the same size as the original.
The licensee could not provide a rationale or basis for doubling up some of the conductors and not others, but explained that as a result of
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the change the chiller 5,ystem worked.
The inspectors also questioned the unavailability of a voltage drop analysis of the circuit given the unusual length of the B chiller circuit which was determined to be 3,100 feet.
The licensee stated that regardless of length, voltage drop analysis for control circuits were not performed; however, power circuits were analyzed for excessive voltage drop.
The inspectors requested that a voltage drop analysis be performed for both Division A and B chiller circuits; that the minimum pickup voltage of the relays be provided; and that a basis for doubling up of only some of the conductors in the chiller circuit be established.
The licensee stated they would comply with the inspectors' requests.
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Although the FCR which identified the voltage drop problem had not been completely signed off, corrective actions had already occurred.
It was the inspectors' concern that an adequate engineering review of the problem had not been properly implemented by means of calculations or analysis.
On August 14, 1985, the inspectors reviewed S&L's acceptance criteria and preliminary results of voltage drop calculations on the control room chiller circuits.
Previously, S&L's standards addressed criteria to review voltage drop on 120V AC control circuits fed from control transformers to ensure that excessive circuit lengths were not used.
S&L stated that AC control circuits, such as the chiller circuits were not reviewed for excessive voltage drop (regardless of length), since their standards do not address AC circuits fed from distribution panels.
S&L has indicated that they are in the process of expanding their voltage drop program to include at least one safety-related division of all AC power and control circuits at Braidwood.
Final results of the voltage drop analyses of the control room chiller circuits were not available during this review but S&L has committed to making the results available in a subsequent inspection.
Pending a review of the above issues, this item is considered to be unresolved (456/85028-03A; 457/85028-03A).
(2) On June 7, 1985, the inspectors accompanied operational analysis testing personnel and witnessed testing of the control room chiller circuitry A and B.
Several points were reviewed on the circuitry schematic diagram, " Control Room Refrigeration Unit 0A Local Control Panel 0W01CA-C,"
drawing 6E-0-4030WO34. The points chosen were termination points L1, L2, 51 and 14 which are inside the local control panel.
Points L1 and L2 are the control power source and neutral, respectively, 51 is on the upstream side and point 14 is on the downstream side of most of the relays in the local control panel. The voltage potentials observed were as follows:
(1) 120V steady state between L1 and ground; (2) 32V on initial relay pickup and 14V steady state between L1 and 51; (3) 94V starting and 114V steady state between 51 and L2
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(During this test the relays chattered and the indicating lights flickered); (4) 120V steady state between L1 and 14; and (5) 87V initial pickup and 111V steady state from 14 to L2.
The results of the tests were not interpreted since the licensee does not have established criteria to monitor voltages at particular points in the circuits.
The licensee stated that voltage drop is not considered if the relays pickup normally with no chatter.
However, with respect to test number 3, relays were noted to be chattering and flickering of the lights were observed.
The licensee could not explain the reason for this abnormal condition.
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In addition to chiller A, the inspectors requested that chiller B also be tested.
The licensee attempted to run two tests, but both failed.
Excessive relay chatter was noted and in both instances the relays in the local control panel failed to pickup.
This matter, in addition to test number 3 for chiller A will be reviewed in a subsequent inspection.
This matter is considered unresolved pending further inspection (456/85028-03B; 457/85028-03B).
(3) During the review of the schematic and wiring diagrams associated with the control room refrigeration units A and B, the inspector observed several discrepancies in the field wiring termination point designations.
Schematic drawing number 20-E-4030WO36, " Control Room Refrigeration Unit 08 Local Panel OW01CB-C," is designated as panel 1AP22E on the neutral side, the correct panel designation is IAP24E.
Additionally, drawings 20-E-3-4030WO36 and 20-E-4030WO34 show two different wire designations between panels 1AP13J and 1AP21E for Division A and 1AP14J and 1AP22E for Division B.
The wire designations between the Division A panels are CRCALCB and CRCALC1 and between Division B panels the designations are CRCBLCB and CRCBLC1.
The wire designations are inconsistent since there are no devices connected between the panels noted above and are therefore inconsistent with the S&L design and drawing conventions.
This matter is considered open pending further inspections (456/85028-04; 457/85028-04).
No violations or deviations were identified; however, the unresolved and open items noted above require further evaluation.
7.
Insaection of the Manual Trip Circuit in Westinghouse-Designed Plants witi Solid State Protection System (SSPS)
The purpose of Temporary Instruction (TI) 2500/14 was to determine whether controlled drawings were being used in Westinghouse designed plants with a Solid State Protection System (SSPS).
The problem involved an erroneous depiction of the manual trip in relation to the output transistors.
The inspectors reviewed selected drawings controlled by the licensee's Central Files department.
A review of the latest revision of Westinghouse schematic number 6058D90 and wire lists 2379A59 and 2374755 indicates that the location of the manual trip was correctly represented on the schematic and is consistent with the wire lists.
In addition, the inspectors examined selected as-built field connections of the transistors for the Division 1 and Divisien 2 UV output circuits for both units.
No problems relating to the TI were identified.
No violation or deviations were identified.
8.
Independent Inspection The inspectors conducted a walkdown inspection of the Unit 1 Auxiliary
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Building.
The inspectors observed two conduits of opposite divisions running into a common junction box.
Instrument Engineered Safety
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Features (ESF) cables 1AR227 and 1AR228 in a Division 1 conduit, violated the cable separation criteria with cables 1AR229, 1AR230, 1AR231 and 1AR232 in a Division 2 conduit.
Braidwood's FSAR, page 8.3-17 requires Class 1E conduits associated with redundant ESF equipment to be separated by one inch.
The inspector observed that the redundant conduits to the junction box were not separated as required.
Additionally, the licensee had not previously performed an analysis or identified this separation violation.
This matter is considered unresolved (456/85028-05;
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457/85028-05).
9.
Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both.
Open items disclosed during the inspection are discussed in Paragraphs 6.a.(1), 6.a.(2), and 6.b.(3).
10. ' Unresolved Items
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Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
Unresolved items disclosed during the inspection are discussed in Paragraphs 6.b.(1), 6.b.(2), and 8.
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Exit Interview The inspector met with the licensee and contractor representatives denoted in Paragraph 1.
The inspectors summarized the scope and
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findings of the inspection.
The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.
The licensee did not identify any such documents / processes as proprietary.
The licensee acknowledged the statements by the inspectors with respect to open and unresolved items.
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