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Insp Rept 50-353/88-12 on 880425-0503.Violation Noted.Major Areas inspected:safety-related Electrical Sys,Components. Emergency Diesel Generator Maint,Electrical Const Insp of Wiring,Cables & Components
	ML20154M087
Person / Time
Site:	Limerick
Issue date:	05/18/1988
From:	Anderson C, Woodard C; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20154M043	List: ML20154M039; ML20154M061; ML20154M087;
References
	50-353-88-12, NUDOCS 8806010169
	Download: ML20154M087 (13)
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U.S. NUCLEAR REGULATORY COMMISSION

-REGION I'

Report No. 50-353/88-12

Docket No. 50-353

License No. CPPR-107 Priority -

Category B

- Licensee: Philadelphia Electric Company

2301 Market Street

Philadelphia, PA -19101

Fa:ility Name: Limerick Nuclear Generating Station, Unit 2

Inspection At: Limerick, Pennsylvania

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Inspection Conducted: April 25 - May 3, 1988

-Inspector: O/0 L C. Cbbrd

C. H. Woodard, Reactor Engineer

r[n[if

date

Approved by: O

Anderson, Chief Plant Systems

(//r/tr

C. J'. date

Section, DRS

Inspection Summan : Inspection on April 2s - May 3,1988 (Report No.

j 50-353/88-12)

Areas Inspected: Routine, onsite unannounced inspection by one region-based

j inspector of activities pertaining to the safety-related electrical systems ,

and components. Specific areas reviewed included emergency diesel generator #

maintenance,~ electrical construction inspection of wiring, cables, and

components.

Results: One violation was identified, 10 CFR 50, Appendix B, Criterion V; i

lack of documented procedures and acceptance criteria for activities affecting

quality in regards to maintenance of the emergency diesel generators.

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8806010169 880525

PDR ADOCK 05000353

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DETAILS

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1.0 -Persons Contacted

1.1 Philadelphia Electric Company

J. Corcoran, Manager Quality Assurance

J. Milito, Superintendent Start-up Support

D. DiPalo, Superintendent, Quality Assurance

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T. Tucker, Assistant Superintendent, Quality Assurance

K. Meck, Assistant Superintendent, Quality Assurance

F. Valentino, Construction Branch Manager

T. Dey, Quality Assurance Engineer

L. Dyer, Quality Assurance Engineer

J. Higgins, Electrical Field Engineering

G. Lauderback, Supervisor Start-up Quality Assurance i

M. Teller, Construction Engineer

1.2 Bechtel Construction Incorporated .

H. Lilligh, Quality Assurance Manager

W. Hatton, Quality Assurance Engineer

B. Foote, Quality Assurance Engineer

G. Kelly, Quality Assurance Engineer

D. Jefferson, Quality Assurance Engineer

N..Roy, Electrical Engineer

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J. Hanze, Quality Control Inspector

j J. Smith, Electrical Superintendent ,

D. Moyer, Meehanical Engineer !

K. Stout, Quality Control Engineer

D. Yenson, Field Engineer '

1.3 Colt Industries

P

J. Schroeder, Field Services Engineer

1.4 U.S. Nuclear Regulatory Commission

R. Gramm, Senior Resident Inspector

R. Fuhremister, Resident Inspector

Denotes those prescnt during the exit meeting.

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2.0 Purpose and Scope

.The purpose of this inspection was to ascertain that the safety-related

electrical wiring, cable,-electrical components.and systems that are in

various stages of construction / installation completion are specified,

procured, installed, maintained, tested and inspected / controlled in such

a manner that they will-perform their -required safety functions. The

scope of this inspection was limited to: the 4160 volt power cable re- ,

placement installation for the "B" emergency diesel generator; pre-operational ,

maintenance of the emergency diesel generators; addressing a licensee

identified problem in the 480V Cutler Hammer motor control centers; and

the electrical construction "blue tag" completion / turn-over procedures.

3.0 Procedures

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The licensee documents relating to the final construction electrical

check-out (blue tagging), the emergency diesel generator installation

maintenance, and electrical caole installation were reviewed. These

documents included construction specifications, drawings, work and *

inspection procedures, and inspection / acceptance criteria.

The review was made to determine whether the technical and administrative ,

requirements of the licensee's FSAR and the NRC requirements had been !

adequately translated into applicable documents to provide for adequate '

work performance and control.

The specific documents reviewed for this inspection are listed in

Appendix A.

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A deficiency was noted regarding inadequate diesel generator maintenance '

procedure, see section 4.1.

4.0 Electrical Systems and Components

4.1 Emergency Diesel Generators

The four Limerick Unit 2 emergency diesel generators are the twelve i

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cylinder Colt /Fairbanks-Morse 81/8 opposed piston type. These units

have been stored in place for several years without operation. Due to

the extensive storage period, the manufacturer recommended (by letter

dated Febr'tary 16,1988) twelve items of inspections, maintenance and

corrective actions which should be performed prior to engine startup.

These recommendations included the following:

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Due to the possibility of chemical action between the crankshafts

and aluminum bearings, the main and connecting rod bearings should

be replaced and the crankshaft journals relapped.

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Inspect cylinder liner bores.

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Replace generator end bearing.

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Flush and inspect engine jacket water, fuel' intercooler, and

lubricating oil systems.

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Hydrostatically test engine jacket water system. -

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Clean engine lubricating oil pan, fill engine system with oil and

inspect all engine lubrication pressure points.

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Inspect engine turbochargers.

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Clean preservative from fuel injection compartment.

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Remove and test all fuel injection nozzles.

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Flush engine governors.

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Check engine alignment.

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Remove and inspect tappet assemblies of cylinders positioned at high ,

Cam.

The licensee had engaged the services of the manufacturer's (Colt) field

service representatives for the lead direction and supervision of the work

associated with the main and connecting rod engine bearings replacement

which was in progress at the time of this inspection. Personnel were

provided by Bechtel to perform the work in accordance with directions,

training and procedures to be suppiied by Colt. Continuous QC surveil- :

lance inspection of the work was performed by bechtel/ licensee personnel. :

This inspection determined that the replacement of the EDG bearings was

being performed by the licensee in accordance with the following:

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Modification Rework (HWR) packages 2AG 501-16, Revision 0 dated

March 28, 1988 (This MWR is for the A EDG, the B, C, and D EDG MWR

packages are the same). These MWR packages include insert sheets

E14, E15, E16 E17, G3 and G4 directly from the vendors manual

covering the removal, inspection, and replacement of the main and

connecting rod oearings (they do not include crankshaf t journal

lapping procedure).

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Verbal instructions from the vendor field services representative

which included the following.

Crankshaf t main, connecting rod and thrust bearing jo rnals

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lapping procedure. ;

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- Proper abrasive lapping material (Tinesaver Products Company

c: Hard Metal Lapping Compound No. 111-Green Label).

Proper tools and aids for use in performing the-lapping and how

.; to use them to achieve the desired bearing journal surface

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finish. Journal finish acceptance criteria.

Precautions with regards to the preparation and use of the

lapping abrasive.

Precautions to prever.t entry of the contaminating lapping

material into other bearings, oil passageways, inverted piston

skirts, and other areas adjacent to the work area.

Procedures and materials to be used to clean the lapping

abrasive from the finished crankshaft journal and adjacent areas.

Cleanliness acceptance criteria (How much if any residual *

lapping compound is acceptable).

Proper lubricant and procedure for application to tha lapped

bearing journals and new bearings prior to asseably.

Engine oil passageways, hold-up volumes, and sumps cleaning

following bearing replacements.

At the time of this inspection the licensee had completed bearings

replacement in the "A" and "C" EDG units and the "B" EDG was in the

proce:s of rework / replacement. Erior to this inrpection, a problem was

identified relative to lapping c.ompound-related bearing daeage in these

same type Fairbanks Morse EDG units at the Getroit Edison Fermi Unit 2

Plant. N: Inspection Report No. 50-341i J46 includes a Franklin

Research report of Fairbanks Morse EDG bearing failures at the Fermi

Unit 2 Plant. One of the fit, dings in this report was betring damage

from crankshaft journal lapping compound, Independent evaluation of the

bearing failures at Fermi's Unit 2 was conducted by Batelle and reported ~

to Detroit Edison on August 31, 1986. Included in this report were find-

ings of bearing damage from journal lapping compounri and a recommendation

to "Improve the method used to remove lapping compound from the crankshaft

journal surfaces." Failure Analysis Asiociates investigation of the

Fairbanks Morse EDG bearing problems re, sort was made to Detroit Edison

during June 1986. It includes the following report paragraph. "The

abrasive component of the bearing conditioner, the Timesaver Lapping

Compound No. 111, was found to have particles up to .002 inch in

diameter. The primary chenical component of the lapping compound is

silica, a hard abrasive material. The presence of these hard particles

in the bearing clearance will cause scratching and scoring of the bearing

surfaces, friction causing excessive heat and thinning of the oil, and can

contribute to breakdown of the oil film and seizure of ths bearing to the

crankshaft."

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An initial review of the Limerick Unit 2 EOG bearing replacement was

conducted with the cognizant ifcensee QA personnel in order to review the

status of the work, the personnel involved in performing the work, the

procedures under which the work was being performed, and the Quality

Assurance Surveillance Inspection program for this work including the

acceptance criteria for the work. Initial concern was expressed by the

inspector since there were no explicit written procedures for performing

, the bearing journals lapping work. The operation including precautions

and acceptance criteria are based upon verbal direction from the vendor

field service representatives. Training of personnel in the work pro- '

cedures and acceptance criteria was hands on and word of mouth type train-

ing. Initial concern was expressed by the inspector to the licensee QA

representative relative to previous problems with connecting rod and main

engine bearings in these same t/pe of EDG units at other plants. The

concerns included those from the Fermi Unit 2 bearing failures in identical

Fairbanks Morse EDG units. Some of the causes of beering damage were

discussed irscluding damage caused by the improper emoval of lapping

comoound (wher, reworking bearings).

The license stated that the procedure in use for removing the lapping ,

compound is to wipe the journal clean with a reg soaked with varsol. A

visual observation and/or rag wipe by the QA inspector is made to vuify

proper removal.

An inspection of the "D" diesel bearings replacement was made of the

removed bearings including the Number 3 connecting rod bearing. A

st.bstantial quantity of the lapping compound (approximctely one teaspoon

full) was observed on the face of this bearing. Sinca this bearing had

, not bun reworked, investigation was made by the licensee to determine the

source of the contaminating lapping compound. Determination was made that

the lapping compound had either flowed through the oil passage from the

adjacent Number 3 main baaring which had been recently lapped or it had

j been accidentally dropped onto the bearing after removal. This finding

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raised questions relative to reworked /new bearings possibly having sub-

l stantial quantities of lapping compound ir, them from adjacent bearings

! through the connecting oil passageways. Seve-al upper crankshaft main and

i connecting rod becrings were disassembled and all were found to have rmall

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quantities of the lapping compound in them. However the new number 10

upper main bearing was found with a substantial amount of lapping material

in it. The entire surface of this bearing was scratched by the lapping

j compound. Apparently the small amount of manual barring (turning) of the

engine while lapping other bearings had been sufficient to cause darage to

this bcaring because of tb ccataminating lapping compound left in it. It

was at the point that all inarings in the engine became suspect fc:'

contamination.

As a consequence of these findings, the licensee took immediate actions

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The bearing journal lapping operation was stopped.

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- The proper procedures for lapping and cleaning the bearing journals

were discussed by the licensee with the Fairbanks Morse field

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service representative. It included a proper sequence of work,

plugging of oil passageways and acceptance criteria. Craft and

quality assurance personnel were instructed by the Fairbanks Morse

and licensee personnel.

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Borescope inspections were made of several upper connecting rod

lubrication passages from the crankshaft journal bearing area down to

the piston wrist pin bearing ("D" EDG unit). No contamination was

observed.

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All "D" EDG unit crankshaf t main and connecting rod bearings were

disassembled. All bearing surfaces were cleaned with fuel oil,

inspected to the new zero-residual-lapping compound criteria, and

the bearings were.then re-assembled. The damaged new Number 10 main

bearing was replaced with another new bearing.

There are twenty four connecting rod and twenty six main bearings in

each EDG engine. Sample inspections of two bearings in each engine were

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made for residual lapping compound contamination in the reworked "A" and

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C" EDG units to establish a basis to either accept "As-Is," to expand the

inspection scope for a greater confidence level, or to remove all bearings

and c7ean (the same as EDG "D",1 Lower main bearings number 8 and 10 on

the "A" unit and numbers 5 and 9 on the "C" unit were inspected. The !

selection of these particular bearings was made because it allowed

inspection of work by both shifts of craftsmen and Q-C inspectors under

the direction of the two different Fairbanks Morse field service repre-

sentative. ~Basod upon these inspections, the licensee decided to accept

. the "A" and "C" EDG units "As-Is."

Interviews were conducted with several of the crafts and Q-C personnel

directly involved in the performance of tais bearing replacement work.

The bearings replacement work is beiag performed by journeyman millwrights.

Lapping of shafts and journals, while not a frequent activity, is considered

, a standard job function for the millwrights and is a standard job skill.

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Two of the millwrights interviewed expressed considerable knowledge and

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experience in the lapping of bearing journals. However they did not have

previous experience with the Fairbanks Morse journal special finishing

. requirements nor were they familiar with the type of lapping compound

- being used.

The inspector expressca further concern beyond the immediate EDG bearing

rework / replacer..ent problems. This concern regards the lack of written

procedures for performing the crankshaft lapping work which could

accompany bearings inspection / replacement at any time during the life of

the EDG units. These bearings are routinely inspected as 6 part of the

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18 month and 5 year surveillances which could involve resurfacing crank-

shaft journals. Without detailed written ~ procedures to assure proper

performance of this effort, including the removal of lapping abrasive

contamination, the EDG bearings and other engine oil lubricated components

are again subject to abrasive damage and possible failure. Further

concern was also expressed for the adequate procedures and controls for

the remaining eleven items of work covered by the Fairbanks Morse,

February 16, 1988 letter.

The lack /ebsence of these procedures both for the current bearing

replacement as well as for bearing work during the life of the EDG units

is a violation of Code of Federal Regulations 10 CFR 50, Appandix B

Criterion V. This portion of the regulations requires the following:

"Activities affecting quality shall be prescribed by documented instruc-

tions, procedures, or drawings of a type appropriate to the circumstances

and shall be accomplished in accordance with these instructions, proce-

dures, or drawings. Instructions procedures, or drawings shall include

appropriate quantitative or qualitative acceptance criteria for determining

that important activities hava been satisfactorily accomplished."

(50-353/88-12-01)

4.2 Motor Control Centers (MCC) Supplied by Cutler Hammer (CH)

4.2.1 Bus Overheating

On April 15, 1988 the licensee reported that the potential exists

for Cutler Hammer supplied MCC aluminum vertical bus bar sections to

overheat thereby causing copper spring-loaded stab connections to

the bus to deteriorate. The licensee report was based upon ex-

perience with similar CH supplied MCC units at the Eddystone

Generating Station (non-nuclear) and upon inforeation provided by

CH. CH reported to the licensee that "the problem seems to be heat

i build-up over a long time span which deteriorates the connection

point between the copper stab and the vertical aluminum bus. The

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heat build-up seems to be caused by the aluminum bus not being a good

enough heat sink to draw the heat away from these connection points.

Aluminum will not disperse a concentrated heat point as rapidly as

copper will due to the density differential in the two metals. This .

problem has occur"ed before and the solution has been to change the

I aluminum bus to copper bus in those sections containing size 4

starters only."

, The licensee performed a visual inspection of all of the CH MCC

Units in Unit 1 during the recent mini-outage. No evidence of

contact burning or degradation was observed. Licensee engins.ering

is currently conducting a study of all of the CH MCC Units and their

loads in order to make an evaluation and establish recoa.mendations

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4.2.2 Defective Bellville Washers

On April 15,1988 the licensee reported finding . multiple instances

of. defective < cenical spring (Bellville) washers during B0P

inspecticn of.CH MCC horizontal copper to vertical aluminum bus bar

bolted connections. The Belleville washers are used to maintain

proper bolted mating pressure between the main horizontal copper bus

and thetindividual vertical aluminum bus sections. The failures

observed consists of the washer becoming segmented by cracking from

the outer to the inner edges. A washer in this condition could fail

to properly maintain contact pressure between the two bus bars,

allowing higher than designed resistance and eventual failure due to <

overheating. Licensee metallurgicai examinations of the failed

washers indicate.that improper process control during the plating

led to hydrogen embrittlement and failure of the washers during or

shortly after tigntening. Both PECO and CH are conducting further

evaluations to conclude root causes of the defects and failures and

to assess their reportability. Disposition of this item to resolve

the problem is dependant upon the licensees actions taken with regards

to the aluminum bus bar heating problem discussed in paragraph 5.2.1.

If the aluminum bus bar is replaced with copper, Belleville washers

will not-be used. However if the bus bar is not replaced, the

licensee is committed to take actions with regards to replacement of

the washers.

Licensee's actions for the foregoing items appear to be adequate. The

inspector had no further questions at this time. ,

4.3 Electrical Power Cable

On September 9s 1988 the licensee reported that the "B" Diesel Generator

Power Cable had failed due to damage incurred while installing / pulling

the cable. The damaged cable did not pass the installation megger test

and requires replacement. The licensee reported that the cable was

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damaged while pulling out of one concrete sleeve and into another :

because of the sharp bending radius and the sharp / abrasive edges on the ;

concrete sleeves.

The licensee has re-evaluated the cable pull and has chipped away some of

the outer edge of the concrete sleeves to permit easier transition of the

cable out of/into the sleeves. Based upon the licensees cable pulling

tension calculation E-622, Revision 0 dated April 26, 1988, it appeared

that the pull can be made without exceeding the maximun pull tension and l

side wall pressura permitted for the types of cable. An independent NRC r

calculation was made of the first segment of the pull in order to verify

the licensee's calculation E-622.

The pulling route and pulling procedures were thoroughly reviewed with

the licensee both in the office and along the pulling route. (Procedures

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t and calculations reviewed are listed in the Appendix to this report.) On

May 3, 1988 the inspector witnessed the successfull pull of the first

segment of the replacement cable and monitored the pulling tension during

r, the pull. The maximum tension measured.was 1050 pounds. This compared

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', favorably with tha maximum calculated expected tension of 2141 pounds and

the maximum allowable tension of 3604 pounds. Inspection was made of the

oulling devicas including the tuggers, the mares tail, cable attachment,

.' proper minfeum bend radius templates and the currdat calibration of the

tension meter. Nf discrepancies were observed in either the cable pulling

procedures, calculations, or in the actual cable puil.

4.4 Electrical Construction Final Inspection for Turn-Over to Start-Up

A review inspection was made of the licensee's program for "Blue Tagging"

electrical components, sub-systems and systems for construction -

completion /verificaticn and turn-over to start-up for pre-operational

tests. The inspection consisted of a review of licensee's procedures,

personnel qualification, and field verification of the implementation of

the procedures. Procedures and documents reviewed are listed in the

Appendix to this report.

An inspection was made of the licensee's blue tag verifications which

were in progress for the emergency diesel generator engine starting

controls in panel 2ETB-AG-501. The drawings in use were verified as the !

latest issue in effect of Colt Industries drawing 11870038 sheets 1-6.

Two inspectors were observed in the process of performing verification of

some of the alarm and annunicator circuits in an alarm and annunicator

panel. The inspectors were observed physically tracing each wire within

the panel to and through each connection and component. The wiring was

verified as to type, size,4dentifications, (arminations and routing.

Each component (relay, switch, terminal block, transformer, etc.) was also

verified. Each wiring circuit was meggered to ensure wiring integrity.

As each wire and component. were verified they were yellowed out on the

drawing. Inspector responses to questions indicated a good understanding

. and knowledge of the work being performed. Their qualifications were

found to be current in accordance with Licensee Qualification Procedure

EE 2.1.

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A review was made of completed and partially completed blue tag inspection

. drawings and records. Each of the drawings and records examined were

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found to be in order with appropriate sign-offs and approvals.

The blue tag inspection / verifications are not normally witnessed by Q-C l

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personnel. However periodic audits are performed to verify that the

inspections are conducted and documented in &ccordance with the latest ,

approved procedures and drawings. A review was made of pECO Audit

Reports AR-2E-227 dated May 5, 1986 and AR-2S-074 dated March 7, 1988.

Except for minor documentation problems, there was no adverse audit

findings.

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5.0 Exit Interview

An exit interview was held on Mav 3, 1988 with members of the licensee

stafi, denoted in paraaraph 1, at the conclusion of the inspection. The

inspector summarized the scope and findings of the inspection at that

time.

No written material was provided to the licensee,

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Appendix A :

Documents Reviewed l

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1.0 ' Final Safety Analysis Report Chapter 8, Electric Power '

2.0' Construction Procedures

E-2 Peimanent Plant Cable Installation and Termination .

- G-3 Long Term Storage / Maintenance / Lubrication of Permanent Plant

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Equipment and Material Prior to Turnover

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E-622 Cable Pulling Calculation for Repull of Cable 2B6501A ;

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E-1412- Wire and Cable, Notes and Details

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M-1 Modification / Rework Packtge MRP 246501-16 to Replace the Diesel ,

Generator Bearings

3.0 Field Engineering Procedures (Blue Tag)

FE-34 Procedure to Inspect and Test 480 VAC Load Center Breakers ,

FE-40 Procedure to Inspect a i Test Medium Voltage Circuit Breakers ,

EE-11.11 Inspection and Testing Procedure Implementation

EE 2.1 Procedure for the Qualification of Fie?d Engineers Assigned to

, Nuclear Power Plants

EE2 1-I Personnel Quali'ication Reccrds of Field Engineers Assigned to '

.

a Nuctaar Power Plant (Including Unit 2 List of Personnel and

theirijualification).

.EE6.3 Procedure to Control Design Documents'used for Insp:-tion and

Test Activities

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4.0 Quality Assurance

2E-213 Quality Assurance Surveillance Check Report Verification of

. Cable Pulling Tension Calculation

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.25-074 Audit Report of PECo Electric Field Engineering Blue Tag

Testing of Safeguard 440 Volt Load Centers

2E-227 Audit Report Inspection of Cutler Hammer Motor Control Center ;

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Appendix A 2

5.0 NRC Reports m

50-341/85-046 Inspection Report of the Detroit Edison Fermi

Nuclear Power Plant Plant, Unit 2 Emergency Diesel

Generator Bearing Failures, July 3,1986.

6.0 Consultants Reports

Franklin Research Center Report to USNRC - Evaluation of Bearing

Failures in Fairbanks Morse Diesel Engines at the Enrico Fermi Unit 2

Reactor, March 3, 1986.

Battelle Final Report to Detroit Edison - A Metallurgical Investigation

of Various Defect on the Surfaces of Diesel Engine Aluminium-Tin

Bearings, August 31, 1986.

Failure Analysis Associates Report to Detroit Edison - Investigation of

Surface Scoring of Main Bearings: Fairbanks Morse 38T08-1/8 Diesels at

Farmt II Power Plant, June 1986. Report FAA-0C-d-86-06-03.

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ML20154M087

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