ML20153B684

Final Significant Deficiency Rept 238-2 Re Use of 600 Volt Type Thhn,Thwn or Thw Wire in 120 Volt Ac Convenience Receptacles & Lighting Circuits for Control Panels.Initially Reported on 880729.Panels,load Ctrs & Switchgear Inspected

ML20153B684
Person / Time
Site:	Limerick
Issue date:	08/25/1988
From:	Kowalski S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Russell W NRC, NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
238-2, NUDOCS 8808310049
Download: ML20153B684 (8)

Text

PHILADELPHIA ELECTRIC COMPANY ~

2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 (as s) ses.4so:

S. J. KOWALSKI VICE PRESIDFNT August 25, 1988

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Mr. W. T. Russell, Administrator United States Nuclear Regulatory ConTnission Attention: Docunent Control Clerk Hall Station P-137 Washington, DC 20555

Subject:

1.imerick Generating Station, Unit 2 Significant Deficiency Report No. 238-2 Use of 600 Volt Type THHN, THWN or THW wire in 120VAC Convenience Receptacles and Lighting Circuits for Safety Related Control Parmis NRC Construction Permit No. CPPR-107

References:

1) Finding Report 2E530, Ju,e 20,1988

2) Nonconformance Report 13547A, July 19, 1988

3) SDR No. 238-2, July 27, 1988

4) Telecon of PECo to NRC, July 29, 1988 Flie:

Qui,1 2-10-2 SDR No. 238-2

Dear Mr. Russell:

In con 011ance with 10CFR50.55Ce), we are submitting our final Significant Deficiency Report concerning use of the above subject wire in safety related panels. This item was verbally reported to Mr. Jim Linville of your organization by telephone on July 29, 1988.

We trust this report satisfactorily resolves the item.

If further information is required, please do not hesitata to contact us.

Since ly RBR/ss/08158801 Copy to:

W. T. Russell, USNRC, Region 1 Admin!strator R. A. Granin, USNRC, LGS 2 Senior Resident inspector R. J. Clark, USNRC, LGS 2 Project Manager

b 8808310049 800825

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NUCLEAR ENGINEERIfG l

ENGINEER!tG DIVISION L

N2-1, 2301 Market Street l

SIGNIFICANT DEFICIENCY REPORT - SDR NO. 238-2 USE OF 600 VOLT TYPE TMN, THWN OR THW WIRE FOR 120 VAC CONVENIENCE RECEPTACLE Ato LIGHTING CIRCUITS IN SAFETY RELATED CONTROL' PANELS l

LIMERICK GENERATING STATION, UNIT 2 i

NRC CONSTRUCTION PERMIT NO. CPPR-107 DESCRIPTION OF DEFICIENCY Philadelphia Electric Conpany NQA issued finding report No. 2E530 on June 20, 1988, which identifled that expnsed PVC Insulated wire was l

Installed In three (3) safety related panels. The wiring does not confonn with the requirements of specification E-1412 "Wire ed Cable Notes and Detalls", Revision 33. The PVC Insulated wire was fleid installed in the panels for non-Class IE 120VAC pcwer for convenience receptacles and light circuits.

The panels against which the Finding Report was written were:

2BC240 RHR "B" Heat Exchanger Lay-up Control Panel 2BC208 Unit Coolers Control Panel 2DC208 Unit Coolers Cont-

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E-1412 was revised August 26, 1982, (Revision No. 18) to_ prohibit l

the use of 600V type TrH4, THWN or THW wire (i.e. PVC Insulated) for l

120VAC power and heater cire:ults In control panels, load centers, KC's and Switchgear. Wire of this type installed prior to August 26, 1982, is allowed if totally enclosed in stoel conduit or in hygrade thermoflex sleeving uo to the wire terTninals. T h PVC Insulated wiring l

observed in the panels was not enclosed in conduit nor sleeved. Also spatial separation between this wiring and Class IE wiring was less than six Inches at various points within the panel. These conditions are in nonconfonnance to E-1412 requirementh The 120VAC pcwer wiring to the pemets for convenience ret.eptacles and Ilght circuits is non-safety relatqd and supplied from a non-Class IE distribution panel. Whenever Class IE and non-Class IE wiring exists in a safety related panel, the Class 1E witing is required to M protected from the non-Class 1E wiring to preVont an electrical' fire h

caused by overcurrent in the non-Class 1E wiring frcm propagating to l

the Class 1E wiring and/or crmponents. Conditions that exlrt in panels l

contrary to these requirti;noots represen. a non-conformanct to design l

and Installation requirements.

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CORRECTIVE ACTION 3

A field inspection of Limerick Unit 2 control panels, load centers, MCC's and switchgear was performed against the requironents of E-1412, Section 9.3 for wiring of 120VAC power and heater ci-cults.

The folicwing panels were Identifled with similar wiring that did not conform to E-1412:

2AC208 Unit Coolers Control Panel 2AC240 RHR "A" Heat Exchanger Lay-up Panel 2AC250 Reactor Enclosure Recirc. System Filter Panel 2CC208 Unit Coolers Control Panel 20C207 Reactor Enclosure Recirc. System HVAC Control Panel 20C234 Drywell Unit Coolers and Steam Flooding Test P:enel 20C901 Heat Tract.g Panels for H2 and 02 Analv%r System 20C901A Heat Tracing Panels for H2 and 02 Analyzer System 20C902 Heat Tracing Panels for H2 and 02 Analyzer System 20C902A Heat Tracing Panels for H2 and 02 Analyzer System 20C906 Bypass Leakage Barrier MOV's Control Panel 20B214 480 Volt Safeguard Motor Control Center An Apparent Discrepancy Notification (L-058) and Nonconformance Report 13547 were lesued June 20, 1988.

The NR was revised July 19, 1988 to include the results of the fleid Inspection report and Fleid Change Request EL-2165.

In accordance with LGS QA Plan, Voltme I, Appendix Z, a reportability ev11uation was started. On Ju'ly 29, 1988 the condition was reported to the NRC as a 10CFR 50.55 Ce) reportable condition.

The nonconforming conditions identified have been reworked and corrected.

If the PVC Insulated wire was six (6) Inches or more from any Class IE wiring or ccrnponents the wiring was sleeved with hygrade thermoflex sleeving.

If the PVC wire was less than six (6) inches away frcm Class 1E wiring or camponents, the wiring was Installed in stainless steel flexible condult.

Fleid Change Request EL 2165 was approved July 6, 1988, This change pennits the use of 600 Volt type TtH1, THWN or TIM wire in panels, load centers, MCC's and Switchgear provided it is totally i

enclosed in stainless steel flexible condult or hygrade thenreflex sleaving up to the wire terminal.

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-ACTION TO PREVENT RECURRENCE 5

All Limerick Unit 2 safety related panels were Inspected and deficiencies were reworked and corrected.

To prevent recurrence, fleid l

personnel were trained on July 14, 1988. The training was given to electrical engineering groups and covered the details of the finding report and the requiremer.ts of E-1412, Section 9.3.,

including Field l

Change Recuest EL 2165.

SAFETY IMPLICATICNS An electrical fire in the non-Class 1E 120VAC pcwer circuit in the prnel could be postulated to spread to the Class 1E w' ring and/or l

component in the panel if the wire was not sleeveu or Installed in condult. This could disable safety systems whose circuits and components are located in che panel from performing their safety function. Colncident with this occurrence a single active fallure postulated to occur in redundant ccrtponents and safety systems could render the plant safety fmettons inoperable.

This could jeopardize plant safety and if left uncorrected could have affected the safe operation of the plant.

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RBR/ss/08128801 j

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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA,19101 (sis) eas.ason S. J. KOWALSKi vacs.PmselosNT C

August 25, 1988

.m..............

Mr. W. T. Russell, Administrator United States Nuclear Regulatory Ccnmission Attention: Docunent Control Clerk Mall Station P-137 Washington, DC 20555

Subject:

Limerick Generating Station, Unit 2 Significant Deficiency Report No. 238-2 Use of 600 Volt Type Ttt-N, THWN or THW wire in 120VAC Convenience Receptacles and Lighting Circuits for Safety Related Control Panels NRC Construction Permit No. CPPR-107

References:

1) Finding Report 2E530, Jme 20,1988

2) Nonconformance Report 13547A, July 19, 1988

3) SDR No. 238-2, July 27, 1988

4) Telecon of PECo to NRC, July 29, 1988 Flie:

Qual 2-10-2 SDR No. 238-2

Dear Mr. Russell:

In ccrnpliance with 10CFR50.55Ce), we are submitting our final Significant Deficiency Report concerning use of the above subject wire In safety related panels.

This item was verbally reported to Mr. Jim Linville of your organization by telephone on July 29, 1988.

We trust this report satisfactorily resolves the item.

If further infonnation is required, please do not hesitate to contact us.

Since ly RBR/ss/08158801 Copy to:

W. T. Russell, USNRC, Region 1 Administrator j

R. A. Granm, USNRC, LGS 2 Senior Resident inspector R. J. Clark, USNRC, LGS 2 Project Manager j

NUCLE.*a ENGINEERING ENGINEERING DIVISION N2-1, 2301 hhrket Street SIGNIFICANT DEFICIENCY REPORT - SDR NO. 238-2 USE OF 600 VOLT TYP' TFfN, THWN OR THW WIRE FOR 120 VAC CONVENIENCE RECEPTACLE NO LIGHTING CIRCUITS IN SAFETY C

RELATED CONTROL PNJELS LIMERICK GENERATING STATICF, UNIT 2 NRC CONSTRUCTION PERMIT NO. CPPR-107

~

DESCRIPTION OF DEFICIENCY Philadelphia Electric Company NQA Issued finding report No. 2E530 on June 20, 1988, which identified that exposed PVC Insulated wire was Installed in three (3) safety related panels. The wiring does not conforTn with the requirements of specification E-1412 dWire and Cable Notes and Datalls", Revision 33. The r'VC Insulated wire was fleid i

installed in the panels for non-Class 1E 120VAC power for convenience receptracles and light circuits.

The nanels against which the Finding Report was written were:

2BC240 RHR "B" Heat Exchanger Lay-up Control Panel 2BC208 Unit Coolers Control Panel 2DC208 Unit Coolers Cont:ol Panel E-1912 was revised August 26, 1982, (Revision No. 18) to prohlblt the use of 600V type THFN, THWN or THW wire (i.e. PVC Insulated) for 120VAC power and heater circults in control panels, load centers, FCC's and Switchgear. Wire of this type Installed prior to August 26, 1982, is allcwed if totally enclosed Ir. teel conduit or in hygrade thermoflex sleeving up to the wire terminals. The PVC Insulated wiring observed in the panels was not enclosed In condult nor sleeved. Also spatial separation between this wiring and Class 1E wiring was less

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than six inches at various points within the panel. These conditions are In nonconformance to E-1412 requirements.

The 120VAC power wiring to the panels for convenience receptacles and 11ght circults is non-safety related and supplied frcm a non-Class 1E distribution panel. Whenever Class IE and non-Class IE wiring exists in a safety related panel, the Class 1E wiring is required to be protected frcm the non-Class 1E wiring to prevent an electrical fire caused by overcurrent in the non-Class IE wiring from propagating to the Class 1E wiring and/or camponents. Conditions that exist in panels contrary to these requirements represent a non-conformance to design and Installation requirements.

. a' CORRECTIVE ACTI(14 A fleid Ir.spection of Limerick Unit 2 control panels, load centers, MCC's and switchgear was perfonned against the requirements of E-1412, Section 9.3 for wiring of 120VAC power and heater circults.

The following panels were Identifled with similar.;! ring that did not conform to E-1412:

C 2AC208 Unit Coolers Control Panel 2AC240 RFR "A" Heat Exchanger Lay-up Panel 2AC250 Reactor Enclosure Recirc. System Filter Panel 2CC208 Unit Coolers Control Panel 20C207 Reactor Enclosure Recirc. System HVAC Control Panel 20C234 Drywell Unit Coolers and Steam Flooding Test Panel 20C901 Heat Tracing Panels for H2 and 02 Analyzer System 20C901A Heat Tracing Panels for H2 and 02 Analyzer System 20C902 Heat Tracing Panels for H2 and 02 Analyzer System 20C902A Heat Tracing Panels for H2 and 02 Analyzer System 20C906 Bypass Leakage Barrier MOV's Control Panel 20B214 480 Volt Safeguard Motor Control Center An Apparent Discrepancy Notification (L-058) and Nonconfonnance Report 13547 were issued June 20, 1988.

The NR was revised July 19, 1988 to Include the results of the fleid Inspection report and Fleid Change Request EL-2165.

In accordance with LGS QA Plan, Volume I, Appendix Z, a reportability evaluation was started. On July 29, 1988 the condition was reported to the NRC as a 10CFR 50.55 (e) reportable condition.

The nonconforming conditions identified have been reworked and corrected.

If the PVC Insulated wire was six (6), Inches or more from any Class IE wiring or ccrrponents the wiring was sleeved with hygrade thermoflex sleeving.

If the PVC wire was less than six (6) Inches away frcrn Class 1E wiring or ccrnoonents, the wiring was Instr.11ed in stainless steel flexible condult.

Field Change Request EL 2165 was approved July 6, 1988. This change pennits the use of 600 Volt type TFH1, THWN or THW wire in panels, load centers, MCC's and Switchgear provided it is totally enclosed in stainless steel flexible conduit or hygrade thermoflex s,1ceving up to the wire terminal.

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ACTION TO PREVENT RECURRENCE All Limerick Unit 2 safety related panels were inspected and deficiencies were reworked and corrected. To prevent recurrence, fleid personnel were trained on July 14, 1998. The training was given to electrical engineering groups and covered the details of the findirig l

report and the requirements of E-1412, Section 9.3.,

including Fleid Char.ge Request EL 2165.

c SAFETY IMPLICATIONS An electrical fire in the non-Class 1E 120VAC power circuit in the panel could be postulated to spread to the Class 1E wiring and/or ccrnponent in the panel If the wire was not sleeved or Installed in condult. This could disable safety systems whose circuits and-l components are located in the panel from performing their safety l

function. Cofrcldent with this occurrence a single active failure postulated to occur in redundant components and safety systems could render the plant safety functions inoperable.

This could jeopardize plant safety and if left uncorrected could have affected the safe-operation of the plant.

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1 RBR/ss/08128P01 l

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