IR 05000352/1985020

Insp Rept 50-352/85-20 on 850401-04.No Violation Noted.Major Areas Inspected:Startup Test Results Evaluation,Main Turbine Testing Activities,Qa/Qc Interfaces & Previous Insp Findings

ML20129G626
Person / Time
Site:	Limerick
Issue date:	05/07/1985
From:	Bettenhausen L, Florek D, Hodson J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20129G595	List: IR 05000352/1985020 ML20129G589
References
50-352-85-20, NUDOCS 8506070324
Download: ML20129G626 (10)

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. , U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-20 Docket N License No. NPF-27 Priority Category C Licensee: . Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Facility Name: Limerick Generating Station, Unit 1 Inspection At: Limerick, Pennsylvania Inspection Conduct d: April 1-4, 1985 Inspectors: *

h D. Florek, Lead Reactor Engineer 'date

\. M J. odson, Reactor Engineer 3 h 15 date

[ w 70, Approvedb[y:L.'_BettenhausF,(, Chief 2f9

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~/ Operations Branch, DRS Inspection Summary: Inspection on April 1-4, 1985 (Inspection Report N /85-20)

Areas Inspected: Routine, onsite, unannounced inspection of the startup program including startup test results evaluation; main turbine testing activities; previous inspection findings; QA/QC interfaces and tours of the facilit The inspection involved 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> onsite by two region based inspector Results: No violations were identifie .

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Details 1.0 Persons Contacted J. Armstrong, Assistant Operating Engineer, PECO C. Bruck, Project Site Manger, GE J. Doering, Operations Engineer, PECO

• P. Duca, Technical Engineer, PECO

• J. Erhm, Start Test Program Scheduler Bechtel C. Endriss, Regulatory Engineer, PECO

• K. Folta, Site QC Supervisor, Gilbert

• G. Gilbody, QA Engineer, PECO

• C. Hermon QA Engineer, PECO K. Hunt, Reactor Engineer, PECO

• A. Jenkins, Startup Test Program Supervisor, GE

• G. Leitch, Plant Superintendent, PECO

• J. Lisa, QA Engineer, PECO ,

• R. Mandick, Test Engineer PEC0 J. Murphy, B0P Test Supervisor, Bechtel

• P. Pagano, NSSS Test Supervisor, GE

• Rekito, Regulatory Engineer, Bechtel C. Williams, QA Engineer, PECO L. Wink, Lead Shift Test Coordinator, GE US Nuclear Regulatory Commission

• J. Wiggins, Senior Resident Inspector

• Denotes those present at exit meeting conducted on April 4, 198 The inspector also contacted other licer.see and contractor personnel in the course of the inspection including reactor operators, startup test engineers and technical staf .0 Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (352/85-06-01), Revisions to STP-14.7 and STP-14.8 to assure discharge pressure is greater than reactor pressure and performance of a breaker operation assessment for those breakers operated during performance of STP-14.9. The inspector reviewed STP-14.7 Revision 1 and STP-14.8 Revision 1 for verificatien of adequate discharge pressur The inspector also reviewed letters S. Rowe to P. Fleckser "STP-14.9 RCIC Loss of AC Power", dated November 21, 1984 and P. Fleckser to R. Ballou

" Advance Test Planning Response RCIC and HPCI Valve Throttling /8attery Loads - RCIC Loss of AC", dated December 7,1984. The licensee evaluation considered battery capacity and energization of connected loads during the test with the breaker lineup as identified and determined that adequate battery capacity exists to support startup testing. This item is close r-

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' Startup Program 3.1 References a' Regulatory Guide 1.68, Revision . 2, " Initial Test Program for Water-Cooled Nuclear Power Reactors"

ANSI 18.7 - 1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants"

Limerick Generating Station (LGS) Technical Specification

• LGS Final Safety Analysis Report

• - LGS Safety Evaluation Report

• NEB 0 23A1918, Revision 0, " Limerick 1 and 2 Startup Test Specification"

• LGS Startup Program Schedule

• : Administrative Procedure A-200, "Startup Test Procedure Format and Content"

• Administrative Procedure A-201, "Startup Test Procedure Control"

Administrative Procedure A-202, "Startup Test Implementation"

• Administrative Procedure A-203, "Startup Test Program Personnel Training and Qualification"

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3.2 Startup Test Results Evaluation Scope 'The startup tests listed in the findings section below were reviewed for the attributes identified _in inspection report 50-352/84-70 Section Findings Except as noted below all the startup test results were found to meet the attributes Lreferenced above. The inspector also assessed that STP-5.6, 14.1 and 14.2 were reviewed and accepted by management. The data was assessed by the inspector in a previous inspectio A summary of each startup test result follow STP-1.2 " Chemistry Data", Revision 0, PORC reviewed results March 15, 198 All acceptance criteria were satisfied except for CRD oxygen content and analysis not available for feedwater metals. TER-90 was identified to'

document this exception and the resolution was accepted by managemen A >

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STP-5.5 " Rated Reactor Pressure Friction Testing", Revision 1, PORC reviewed results March 14, 198 Acceptance criteria were satisfied. Several test exceptions were identified during the test which affected test methodolog All were resolved and accepted by managemen STP-5.7 Rated Reactor Pressure Insert / Withdraw Checks and Scram Testing of Selected Rods", Revision 1, Test implemented January 27, 198 Management review was completed and test results were approved. The four selected rods were 10-39, 26-39, 30-35 and 38-27. These rods will be monitored for scram times during planned scrams. Acceptance criteria were satisfie STP- " Reference Leg Temperature Comparisons", Revision 1, Test implemented January 24, 198 Management review was completed and test results were approve The acceptance criteria were satisfied with the difference between the initial

- calibrations and actual reference leg temperature producing an end point error of less than 1* STP-11.1-2 " Verification of Proper Connection of LPRM Detectors and Readout Equipment", Revision 1, Test implemented January 16, 198 Management reviewed and accepted test result ,

STP-13.2-1 "TIP Alignment at Rated Temperature", Revision 1, Test implemented January 23, 198 One test exception was identified due to TIP-E not beirg able to be tested during this attemp It' will be tested at a later dat Management review and acceptance of the test results were complete STP-14.3 "RCIC- Stability Check CST to CST at 150 psig", Revision 1, PORC reviewed results March 14, 198 Two test exceptions were identified. During the quick start portion, RCIC achieved greater than 600 gpm but did not respond to demanded control changes. The test was repeated successfully af ter valves were stroked. Alignment of the servo will be performed and further tests will be performed. Some oscillatory behavior was noted but was judged to be acceptable for this testing conditio STP-17.1 " Measured Pipe Displacement (Selected B0P Systems)", Revision 1, PORC reviewed results March 13, 198 '

Test results reviewed were from tests performed at 275 F, 350 F and 450 Level two acceptance criteria failures were identified and documented. Test results were accepted by management, l

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STP-17.3 " Measured Pipe Displacements (Main Steam Inside Drywell and Reactor Recirculation)", Revision The test was conducted three times at reactor recirculation temperatures of 260 , 450 F and 530 F on December 30, 1984, January 5, 1985 and January 10, 1985. Two test exceptions were identified (TER-22 and 29)

for level 1 acceptance criteria failure These test exceptions were discussed in inspection report 50-352/85-0 The test results were accepted by managemen STP-17.4 " Visual Inspection (Main Steam Inside Drywell and Reactor Recirculation)", Revision 0, PORC results approved March 13, 198 Acceptance criteria were satisfied with re3ults accepted by managemen STP-70.3 "RWCU Normal Mode Performance Verification", Revision 1, PORC results reviewed March 15, 198 Acceptance criteria were satisfied and results were accepted by managemen .0 Main Turbine Testing under the low power licens Scope The inspector reviewed the licensee plans and procedures used to conduct the planned testing of the turbine generator under the low power license to ensure that there is reasonable assurance that the activities can be conducted in a safe manner and not exceed the licence condition The inspector interviewed several senior licensee representatives including the Plant Superintendent, Operations Engineer, Technical Engineer, Reactor Engineer, GE FPS Project Site Manager, GE Startup Test Group Supervisor and members of their staff. The following documents were also reviewed:

Letter S. Daltroff to H. R. Denton dated March 25, 1985 requesting NRR concurrence in licensee plans to operate the main turbine within the 5's steady state license power limi * PECO Safety Evaluation for operation of the Main Turbine Generator under Operating License NPF-27 draft cop *

SP-GP-006 " Main Turbine Initial Startup", Revision 0

SP-GP-XX " Shutdown of Main Turbine During Low Power Testing",

In preparation copy, Rev. *

GP-2 " Normal Plant Startup", Revision 4, dated February 14, 1985

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• Letter C. Bruck to G. Leitch dated December 10, 1984 " Initial Start and Low Power (Main Turbire) Operation".

• Schedule T6-1003 Initial Turbine Roll / Generator Sync

• Schedule STP-3028 Startup Test Program One Week Schedule

Time history plot from STP-15.2-6 "HPCI Quick Start at Rated CST to CST" performed March 12, 198 * Data from Susquehanna Steam Electric Station on turbine roll steam demands dated January 22, 1985 and February 1,1985

IP-93.2 " Main Turbine Control System", Pre-op data for turbine bypass and control valve testing on September 24, 198 *

Technical paper "Feedwater Flow Measurements" by M. Torres, dated February 10-14, 1985 Findings Based on the interviews conducted, the licensee plans to roll the main turbine with no additional heat balances conducted to reduce the conser-vatisms in effect with actual core thermal power and indicated core thermal power. If the licensee cannot supply the steam necessary to achieve main turbine rated speed, they may modify their plans and utilize an ultrasonic flow meter on the feedwater lines to improve heat balance accurac If this device was used, further information would be required on the previous experience, calibration, testing, and uncertainty analyses to determine acceptability of tnis approach. This was identified at the exit meeting and was acknowledged by the license Based on the turbine vendor estimate and data available from Susquehanna the required steam demand to achieve rated turbine speed is between 200,000 - 400,000 pounds per hour Inspector observations during steady state operation (testing) at less than 5 percent power indicates that approximately 390,000 pounds per hour will be available for turbine testing without exceeding the license power limit. Therefore sufficient steam is probably available to achieve rated turbine speed. Licensee precautions and limits are further discussed belo The license plans to conduct turbine testing in discrete steps (shell warming, sounding roll, roll to rated and generator synchronization).

The licensee plans to review plant response to the previous testing and extrapolate plant response to future testing and evaluate whether future testing is appropriat In addition the licensee plans to define constraints in testing beyond which attempts to obtain the desired end point will not be further pursue These plans have not yet been developed in detai _ r ,

7 While generator synchronization is contained in the test procedure, steam limitations may preclude it from being conducted under the low power licens Inspector review of the EHC Preoperational data indicated that turbine bypass valve (TBV), control valve (CV), and main stop valve (MSV)

stroke time testing satisfied acceptance criteria and that EHC response to simulated turbine roll and pressure changes were acceptabl Review of HPCI quick start testing which demanded essentially step changes in steam flows of approximately 197,000 pounds per hour were acceptably controlled by the EHC system. This is representative of the low end of steam flows necessary to achieve rated main turbine spee Inspector review of the PECO safety evaluation and SP-GP-006 indicates that the licensee plans to perform the turbine testing with the mode switch in "Startup" with administrative controls that require the operator to scram the reactor and close the MSIVs if low pressure is sensed at the inlet to the high pressure turbine. This is an automatic MSIV action when the mode switch is in RUN and is consistent with previous plant operation under the low power license. This also assures more sensitive power level trips from the IRM and APR Inspector review of the interfacing of procedures SP-GP-006 and GP-2 indicated differences in initial conditions for turbine roll activitie The interfacing of GP-2 and schedule STP-3028 also indicated different conditions for performing shell warming operation The licensee representative indicated the proper interfacing of these documents is in proces In addition the licensee representative indicated that an additional procedure is being developed to assure that the license power limit would not be exceeded when shutting down the turbine. A draft copy was reviewed by the inspecto The training of the operators in the initial turbine roll has not been completed. Training will be conducted and a walk thru of the procedures will be performed with the operating staf The normal plant configu-ration to roll and synchronize the turbine generator is two turbine bypass valves open which is not too different from the conditions planned for the initial turbine roll with one turbine bypass valve open. Mode switch in

"Startup" vs "RUN" requires additional monitoring of steam line pressure for manual scram and MSIV closure for EHC failures. Training of the operators in this' mode of operation will be accomplishe Loss of pressure control capability of the EHC will be protected during this event by the RPS and administrative control High pressure protection is provided by the pressure and IRM/APRM trips in the Startup Mode. Low pressure protection is provided by operator monitoring of the steam line pressure and scramming the reactor and closing the MSIVs. This is consistent with previous operation under the low power license. If MSIV closure occurs, RCIC, and CRD pumps are capable of injecting water into the vessel at high and low pressure and have been tested / operated for

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vessel injectio HPCI Is also capable of vessel injection but is not required to be tested until much later in the startup progra MSIV

! functional testing has also been successfully completed in the startup program.

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In summt /, the inspector concluded that initial turbine roll activities under the low power license can be conducted in a safe manner. All plan-ned turbine testing may not be accomplished due_ to the available steam

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supply; however, achieving rated turbine speed is expected. Previous

- plant testing is comparable to conditions expected for turbine roll activitie The licensee's detailed planning is not complete but must be completed prior to the initial turbine roll activities to assure safe conduct of the test. These activities are listed below and collectively constitute unresolved item (352/85-20-01). Issue final PECO safety evaluation Integrate SP-GP-006 and GP-2 Integrate GP-2 and STP-3028 Issue procedure for not exceeding low power license constraints on l shutdown of the main turbine generato . Training of personnel for initial turbine roll.

Review plant response after each test phase and determine acceptability of proceeding into the next phas . Define limits on plant operations in achieving the end point desired in.each testing phase.

, The licensee representative acknowledged the inspector findings at the ,

exit meeting. The inspector _ also noted that prior NRC acceptance of the .

above items is not a constraint on the licensee's turbine roll activities but that the licensee's actions to satisfy the above items will be assessed in a subsequent inspectio .0 QA/QC_ Interfaces Based on review of STP-99.2, the inspector determined that QC has reviewed completed startup test procedures as required by the administrative procedures. Based on an interview with a QC engineer, QC surveillance of l STP-14.5 and STP-17.1 was in process. The inspector reviewed in process

! surveillance report CEW-85-X covering the in process surveillance. No unacceptable conditions were note ,

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Plant Tours

' The inspector made several tours of the facility during the course of the inspection including the reactor building, turbine building, control structure and control room. No unacceptable conditions were note . Exit Interview An exit meeting was' held on '. April- 4, 1985 to discuss the inspection findings as detailed in this report. (See paragraph I for attendees).

At no time durieg the inspection did the inspector provide written inspection findings to the license At the exit, the licensee did not identify any proprietary material that was contained within the scope of the inspectio .

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