IR 05000353/1987006

Insp Rept 50-353/87-06 on 870504-15.Deviations Noted: Licensee Has Not Provided Evidence to Demonstrate Completion of Design Changes Required or Physical Installations to Provide for Required Voltage Levels to Class 1E Components

ML20215F225
Person / Time
Site:	Limerick
Issue date:	06/08/1987
From:	Anderson C, Woodard C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20215F191	List: ML20215F188 ML20215F207 ML20215F225
References
50-353-87-06, 50-353-87-6, IEIN-77-01, IEIN-77-1, IEIN-82-04, IEIN-82-4, NUDOCS 8706220285
Download: ML20215F225 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No, 50-353/87-06 Docket N License No. CPPR-107 Priority - - Category B Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Facility Name: Limerick Nuclear Generating Station, Unit 2 Inspection At: Limerick Generating Station Inspection Conducted: May 4-15, 1987 Inspectors: E [/#b Deg & /SB7 Carl H. Woodard',~ Reactor ' Engineer date

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Approved by: C 37 C. JUAnderson, Chief Plant Systems date !

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Section, DRS Inspection Summary: Inspection on May 4-15, 1987 (Inspection Report No. 50-353/87-06)

Areas Inspected: Routine, onsite, unannounced inspection by one region-based i inspector of activities pertaining to the safety-related electrical systems !

and component Results: One deviation and two unresolved items were identifie 'l 8706220265 870615 3 j PDR ADOCK 0500 G

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DETAILS 1.0 Persons Contacted i l

1.1 Philadelphia Electric l

• G. Lauderback, Quality Assurance Branch Head

• P. Naugle, Assistant Construction Superintendent

• J. Harding, Lead Facility Engineer

• T. Tucker, Quality Assurance Engineer

• J. Corcoran, Manager, Quality Assurance

• P. DiPaolo, Quality Assurance Branch Head G. Tepper, Electrical Engineer W. Shraff, Electrical Department Branch Head W. Coyle, Electrical Project Engineer C. Tuttle, Electrical Project Engineer R. Panunto, Electrical Facilities Engineer T. Dey, Quality Assurance Enginee .2 Bechtel

• W. Bradley, Quality Assurance Engineer

• S. Loofbourrow, Quality Assurance Engineer

• G. Kelly, Quality Assurance Engineer

• D. Harder, Qaulity Assurance Engineer

• B. Mukherjee, Project Engineer M. Drucker, Quality Assurance Engineer G. Bell, Quality Assurance Engineer G. Konecny, Quality Assurance Engineer K. Stout, Quality Assurance Engineer M. Dixon, Cable Yard Foreman M. Twardowski, Lead Long Term Maintenance Engineer R. Sewell, Electrical Engineer N. Roy, Electrical Engineer J. Schwamb, Lead Maintenance Quality Assurance Engineer 1.3 Nuclear Regulatory Commission

• R. Gramm, Senior Resident Inspector

• J. Kaucher, Resident Inspector

• Attendees at exit interview on May 14, 198 .0 Procedure Review A sample of the licensee's documents associated with the procurement, storage, installation and inspection of the class IE electric system components including wire and cable as listed in Attachment A were reviewed by the inspecto .

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j This review was to ascertain whether the technical elements of the

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licensee's safety analysis report (SAR) and NRC requirements had been adequately translated into applicable documents. Also, to determine if the construction specifications, drawings, work procedures and instructions were of sufficient detail and clarity to perform and control the work, No deficiencies were identifie .0 Record Review A sample of licensee records, associated with the class IE electric systems was reviewed by the inspector. These records are listed in Attachment This review was to ascertain the effectiveness of the licensee quality assurance program in the areas of procurement, storage, work activities and inspection of the class IE electric systems to assure that the systems and components perform their safety-related function No deficiencies were identifie .0 Electrical Components and Systems - Work Observation The inspector observed work in progress and completed work to determine whether activities related to safety-related electrical systems and components are being controlled and accomplished in accordance with NRC >

requirements, safety analysis report commitments, and licensee procedure .1 Electrical Installations The following installed electrical systems and components were observed by the inspecto The B Train Emergency Diesel Generator System

- 4 Kv Safeguards Switchgear Panels

- 480 Volt Safeguards Load Center Panels

- Reactor Enclosure Damper Indicator / Control / Test Panel

- ATWS 4.16 Kv Switchgear Panel

- 125 Volt DC Battery Room 361 The following electrical systems work in progress was observed by the inspector

- Replacement of Agastat 7000 series relays in the B Diesel Generator Engine Control Panel with Agastat ETR series relays. This replacement was in response to Information Notices 77-01 and 82-0 !

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- In place storage / maintenance program for the. emergency diesel generator Observations made by the inspector included the followin The components and panels were properly identifie Protective dust covers were in place over the equipments / panel Protective plywood covers were installed around the bases of panels in heavy ~ construction activity area Electrical space heaters were properly energized in electrical panels-and generator Components were installed in the correct locations with the correct orientatio Electrical separation was maintaine Electrical installation was being performed with approved procedure Where cable had been pulled to panels but not terminated, it was wrapped with protective paper, the ends were taped and it was neatly-coiled to an acceptable radius and secured with tyrap In place storage / maintenance of the diesel generators was in accordance with the manufacturers recommendations and approved licensee procedure No violations were identifie .0 Electric Cable-Work Observation The inspector reviewed activities related to safety related cables for safety related systems to determine if they are controlled and accomplished in accordance with NRC requirements, safety analysis report commitments and license procedures. This included direct observations and an inde-pendant evaluation of work performance, work in progress and completed wor ,

5.1 Storage The following storage /maintanenance attributes of licensee construction procedures CP-E-2 and CP-F-2 were observed by the inspector in the cable receipt / storage / cut yard (Note: All permanent in plant cable is procured to the same "Q" Specification requirements regardless of the application (Q or Non-Q) except for GE furnished "non Q" PGCC cable).

- Permanent plant cable and PGCC (Q and Non Q) were stored / maintained in separate areas of the cable yar Master cable reels (as received from the manufacturer) were identified with manufacturer's information and the Bechtel cable code to provide cable identity and traceabilit Sub-master cable reels were provided identity to provide traceability to the master ree Cable ends were sealed with end caps or tap l

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- Cable reels were stored above the concrete / ground to preclude cable contact with surface water, j

- Temporary cable was stored in a remote area with a large letter I

"T" painted on the cable reel Licensee procedure CP-F-2 requires that the temperatures of cable on reels be above 10' F for removal of cable. The cable tempera- ;

ture upon removal was not currently being recorded. The cable yard foreman stated that when weather is cold, reels of cable are brought inside to warm up prior to cable removal. This is an unresolved item (50-353/87-06-01) pending licensee demonstration of the adequacy of existing controls for cable already pulled and the potential need for additional controls for future cable pull The following cable storage / maintenance attributes were observed by the inspector in the permanent plant pre-cut cable laydown (interim storage) area outside the turbine buildin Pre-cut cable lengths were each uniquely identified by attached labels which included the application information (pull from location to destination) and traceability back to the master reel from which it was pulle Construction procedure CP-E-2 paragraph 5.2.3.22 requires measures to " assure that cable in interim storage pending installations is adequately protected including maintaining the reels in an upright position, preventing cable contact with surface water or ground."

Some of the pre-cut cable in the laydown area was found to be on reels and stored in an upright position; however, most of the pre-cut cable was in tied coils. The coils were stored off the ground on wooden pallets. The inspector observed this area daily from May 4-14, 1987. On May 13 the inspector observed a few cable coils (approximately 20) which were not stored on pallets so as to keep the cable off the ground and away from water submersion damage. These cable coils were stored on a plastic sheet. The inspector noted that the plastic sheets were dry and there was no contact of the cables with water. The inspector pointed out to the licensee that at a future time rainwater could pool on the plastic and expose the cables to wate The licensee agreed and took prompt action to place the subject cable coils off the ground on wooden pallet Further, since the cable storage procedure, CP-E-2 paragraph 5.2.3-22 did not specifically address coils of cable off the cable reels the licensee agreed to issue a clarifying memo to this procedure. The licensee's proposed corrective actions in-clude revisions paragraph 5.2.3.22 to the procedure and providing instructions to cable handling personnel in proper storage practices. This is an unresolved item pending licensee development of a procedure to control the temporary storage and protection of coils of cable that are not on cable reels. (50-353/87-06-02)

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5.2 Electrical Cable-Installation Recorded installation data for several class IE cable installations was reviewed for conformance with specification 8031-E-1412 and construction procedure CP-E-2. The calculated maximum cable pulling tension and sidewall pressure for the installed cables was compared to the data recorded during the installation. In all cases the actual pull tension and sidewall pressure was determined to be less l than the specified limit The inspector reviewed cable calculations E-587 for cable pull j t package SE.01076. This was a bulk pull of six single conductor 500 s KCMIL and one single conductor 250 KCMIL cables through a five inch PVC conduit from Safeguards Load Center Distribution Panel 20B201 to MCC Panel 20B12 The inspector witnessed a portion of the pull which was from Junction box 2AJ019 elevation 313' to junction box 2AJ020 elevation 299' and then to the cable duct at elevation 269' which led to panel 20B129. The maximum allowable cable pull tension was 2245 pound Calculated expected maximum pull tension was 1486 pounds. However, as a result of the good cable and conduit prelubrication, the pull was made with a maximum of five men pulling by hand. The pull tension was estimated to be not in excess of 500 pounds based upon

.an average tension per man of 100 pounds per paragraph 2.1.3 of specification E-141 No deficiencies were observed in either the cable pulling procedure, records, calculations or the actual cable pull witnesse .3 Electrical Conduit and Cable Tray Installation The inspector observed installed cable tray and conduit at various locations throughout the plant. Inspections were made of conduits 2CLO46 from Motor Control Center MCC 20B221 to MCC 20B217 and conduit 2CLO47 from Motor Control Center MCC 20B221 to MCC 20B217 and conduit 2CL047 from Motor Control Center MCC 20B217 to RHR pump 2AP21 No deficiencies were observed in the identification, routing, configuration, or seismic supports for these conduit i

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5.4 Electrical Cable Terminations The inspector observed wire and cable terminations in load centers, l motor control centers, fuse panels, and in control cabinets at !

several locations. An inspection was made of licensee cable termi- j nations in Motor Control Centers MCC 20B221 and MCC 20B217 of cable which was installed in accordance with cable schemes CB217-03A and CB217-04A. In addition, an inspection was made of control wire terminations made by licensee in the "B" emergency diesel generator engine control panel. No deficier:cies were observe '

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6.0 Electrical Distribution System 6.1 Adequacy of Electrical Distribution System to Provide Required Voltage Levels to Class IE Equipmen The inspector reviewed the licensee's voltage profile studies and a licensee letter to NRC dated October 22, 1981, in which low voltage problems in certain class IE circuits were identified under Signi-ficant Deficiency Report No. 52 for both Limerick Units #1 and # In this letter the licensee confirmed a previous 50.55(e) telecon to )

the NRC in which potential undervoltage conditions for 166 safety j related circuits were reported. Commitments were made by the i licensee to the NRC, in this letter, to complete design changes and installation to correct the affected circuits for Unit 2 by June 3'

198 ll The inspector reviewed the Bechtel " Final Report on Undervoltage Problems in Certain Power And Control Circuits For LGS Unit #1 And Common" dated February 1983 in which corrective actions were detailed to correct a total of 534 deficient circuits for Unit #1 and circuits common to Units 1 and The inspector was unable to locate a record of design changes and installation in Unit 2 to correct the under-voltage deficient circuit This technical item is a construction deficiency outstanding open item (50-353/80-00-12). Failure to meet the Unit 2 June 1986 commitment to NRC is a deviation to their commitmen (50-353/87-06-03)

7.0 Definition of Unresolved Items Unresolved items are matters about which more information 13 required in order to ascertain whether they are acceptable, violations, or deviations relative to the bulletin requirements. Unresolved items identificd ,

during this inspection are discussed in paragraphs 5 and 6 abov '

8.0 Exit Meeting The NRC inspector conducted an exit meeting on May 14, 1987 with licensee ,

representative (denoted in paragraph 1). The NRC inspector summarized the '

inspection findings and the licensee acknowledged these comments. No l written material was provided to licensee personne i a

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Attachment A Documents Reviewed 1.0 Final Safety Analysis Report, Chapter 8 - Electric Power 2.0 Construction Procedures (CP)

D-1 Processing of Nonconformence Reports, Rev. 4, 6/26/86 D-7 Construction Administration Control, Rev. 8, 5/20/87 E-1 Electrical Panel Modifications, Rev. 6, 5/20/87 E-2 Permanent Plant Cable Installation and Termination, Rev. 3, 2/2/87 E-3 Electrical Raceway, Rev. 3, 10/15/86 G-3 ' Long Term Storage / Maintenance / Lubrication of Permanent Plant Equipment and Materials Prior to Turnover, Rev. 3, 10/22/86 F-2 Receipt Inspection-Storage and Withdrawal of Materials / Equipment, Rev. 9, 5/18/87 3.0 Drawings E-1412 Wire and Cable Notes and Detail, Rev. 30, 2/4/87 E-1406 Conduit and Cable Tray Notes, Symbols and Details, Rev. 6, 5/6/87 E-1420 Maximum Allowable Cable Length - Power and Control Circuits, Rev.1, 12/14/83 E-66 Single Line Meter and Relay Diagram, MCC Load Tabulation, Rev. 5, 4/26/83 E-159 Load Center SWGR-MCC FDR Bkrs. 440v, Rev. 27, 1/23/87 E-160 Safeguard Buses - 101 and 201, Safeguard Bus Feeders, 4Kv, Rev. 19, 1/3/85 E-162 Safeguard Buses - Load Center Transformer Bkrs. 4Kv, Rev. 6, 12/14/82 E-163 Safeguard Buses - Load Center Transformer Bkrs. 4Kv, Rev. 12, 1/7/85 E-164 Safeguard Buses - Generator Bkrs 4Kv, Rev. 19, 10/18/84 E-1 Single Line Diagram - Station, Rev. 13, 4/26/85 E-16 Single Line Meter and Relay Diagram, 4Kv Safeguard Power System, Rev. 15, 8/1/85 E-29 Single Line Meter and Relay Diagram, 0214, D224, D234, D244, Safeguard Load Centers, 440 volt, Rev. 10, 12/18/85 4.0 Reports

- Significant Deficiency Report No. 52 - Undervoltage Condition in Certain Electrical Power and Control Circuits, 10/22/81

- Final Report on Undervoltage Problems in Certain Power and Control Circuits for LGS Unit 1 and Common, 2/16/83 l

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5.0 Quality Records PECO Audit Reports 2E-230 GE Cable Installation (5/8 - 5/19/86)

2E-245 Diesel Generator Control Panels (12/16 - 12/31/86)

2E-227 Motor Control Center 20B224 (3/25 - 4/2/86)

2E-248 Cable Pulling of PGCC Cables (2/13 - 2/20/87)

2E-225 Material Control (11/13 - 11/20/85)

2E-236 Electrical Cable Storage Program (7/10 - 7/31/86)

2E-180 Control of Electrical Parts and Components (11/13 - 11/20/85)

Maintenance Action Records for In Storage Maintenance of "B" Emergency Diesel Generator 6.0 Calculations E-587 Cable Pulling Tension, 4/27/87 E-590 Cable Pulling Tension, 5/4/87 LGS Units 1 and 2 Final Calculations Index EE.350 Bechtel Computer Program Manual for Cable Tension Calculation I J