IR 05000352/1986005

Insp Rept 50-352/86-05 on 860224-28.No Violation Noted.Major Areas Inspected:Startup Test Program,Including Startup Test Results Evaluations,Plateau Review,Qa/Qc Interfaces W/Startup & Independent Measurements

ML20202E913
Person / Time
Site:	Limerick
Issue date:	04/04/1986
From:	Eselgroth P, Florek D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20202E884	List: IR 05000352/1986005 ML20202E880
References
50-352-86-05, 50-352-86-5, NUDOCS 8604140072
Download: ML20202E913 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-05 Docket No. 50-352 License N NPF-39 Category C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania Facility Name: Limer.ick Nuclear Generating Station Inspection At: Limerick, Pennsylvania l Inspection Conducted: February 24-28, 1986

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Inspector:

07 Flore'li," L f-9 - M

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,~ Reactor Engineer, datt TPS, OB, D Approved by:

P. Eselgroth

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ief, Test Programs Section h- b k date 08, DRS

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Inspection Summary: Inspection on February 24-28, 1986 (Inspection Report: 50-352/86-05)

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. Areas Inspected: Routine unannounced inspection of the startup test program following the completion of the startup testing activities including startup l test results evaluations, review of test exceptions, overall program, plateau review, QA/QC interfaces with startup, and independent measurements, calcula-tions and verification 'Results: No violations were identified. NOTE: For acronyms not defined refer to NUREG-0544 " Handbook of Acronyms and Initialisms".

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f 8604140072 860407 PDR ADOCK 05000352 0 PDR

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DETAILS 1.0 Persons Contacted J. Armstrong, Assistant Operations Engineer D. Atkinson, NSSS Test Supervisor

• R. Ballou, GE Operations Superintendent C. Endriss, Regulatory Engineer P. Fleckser, Startup Test Scheduler

• J. Frantz, Superintendent of Operations A. Jenkins, Startup Test Program Supervisor

• G. Leitch, Plant Manager

• J. McElwain, QA Auditor

• J. Rubert, QA Site Supervisor

• V. Warren, Test Engineer U.S. Nuclear Regulatory Commission E. Kelly, Senior Resident Inspector

• Denotes those present at the exit meeting on February 28, 1986.

2.0 Startup Program References

• 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

• Specification 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" l

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• Administrative. Procedure A-203, "Startup Test Program Personnel Training and Qualification" 2.1 -Test Results' Evaluation Scope The startup test results from TC-6 listed in the discussion section below were reviewed for the attributes identified in inspection re-port 50-352/84-70 section In addition 19 startup test results from TC-4 and TC-5 reviewed in previous inspections, but for which the management review cycle was not completed at that time, were also reviewed for completion of the management review cycl Discussion Management review and acceptance of test results were completed for all the TC-4 and 5 testing. The attributes for the TC-6 test results were found to be satisfied. A summary of each startup test reviewed follow STP 1.2 " Chemistry Data", Revision 0, test implemented January 2,198 The test was performed at 99.5* powe Key reactor water chemistry results were:

Value Limit conductivity micromho/cm .325 < chloride ppb <20 <200 pH .6<pH< Appropriate acceptance critera were satisfie STP-2.1 " Radiation Surveys", Revision 1, test implemented December 27, 198 The test was performed at greater than 95% power. Two inplant points exceeded the allowable dose rates and were respecified as a more restrictive radiation zon STP-5.8 " Scram. Timing of Selected Rods During Planned Scrams of the Startup Test Program", Revision 1, test implemented December 18, 1985 and January 2,198 _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ - _ - _ _ _ _ _ ____ __-

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This test was performed in conjunction with the MSIV full closure test and turbine trip test during TC- Time to 05 Time to 05 Rod MSIV Turbine Trip Limit 26-39 .3 3.49 se .46 2.49 38-27 2.45 2.45 10-39 2.54 2.54 STP-12.3 "High Power APRM Calibration", Revision 1, test implemented December 28, 198 APRM's were adjusted to read equal to or greater than core thermal powe STP-11.3 "LPRM Calibration With P ocess Computer", Revision 1, test implemented December 27, 198 Except for five LPRM's, the gain adjustment factors satisfied the acceptance criteria. A test exception was prepared for the five LPRM' STP-13.8 " Acceptance Criteria Verification", Revision 2, test implemented January 1, 198 A comparison was made using the process computer and backup metho Limiting MFLCPR Sundle BUCLE Process Computer 39-18 .837 .838 39-44 .837 .838 21-18 .837 .838 21-44 .837 .838 Limiting MFLPD Location BUCLE Process Computer 13-38-8 .922 .922 13-24-8 .922 .922 47-38-8 .922 .922 47-24-8 .922 .922

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Limiting MAPRAT Location BUCLE Process Computer 13-24-8 .924 .925 47-24-8 .924 .925 47-38-8 .924 .925 13-38-8 .924 .925 The results indicate that the process computer and BUCLE method are providing equivalent result STP-16.3 " Recirculation Pump Trip Recovery Data", Revision 0, test implemented January 22, 198 The temperature differences and flow rate limits prior to re-start of a tripped recirculation pump were satisfied during this tes STP-17.2 " Measured Pipe Displacements Feedwater System", Revision 2, test implemented January 22, 198 The test was performed at near rated power. Acceptance criteria were satisfie STP-17.3 " Measured Pipe Displacements - Main Steam Inside Drywell and Reactor Recirc.", Revision 1, test implemented January 23, 198 The test was performed at near rated power. Test exceptions identified were processed in accordance with the administrative procedur STP-18.1 "TIP Uncertainty Determination", Revision 0, test implemented January 22, 198 The average total TIP uncertainty of 3.23% satisfied the test criteria of less than 6%.

STP-19.2 " Process Computer Calculation", Revision 1, test implemented December 28, 198 With the reactor at 98% power, CMFLPD = .879 CMFCP = .818 CMAPR = .876 which satisfied the test criteri l f

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STP-22.1 " Pressure Regulator Response-Control Valve Operation",

~ Revision 0, test imp'lemented January 12,.198 With the reactor at 98 4% power no unacceptable oscillations

were noted during the pressure, regulator tests. Margins to scram were acceptabl STP-22.3 " Pressure Regulator Respons~e --Bypass Valve Operation",

Revision 1, test implemented December 30, 198 With the reactor at 98.4% power no unacceptable oscillations were noted. Margins to scram were acceptabl STP-23.4 " Loss of Feedwater Heating", Revision 0, test implemented January 12, 198 With the reactor at 86.1% power,and total core flow of 99.5% a

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loss of feedwater heating was ihittated by isolating the fourth stage extraction steam. This resulted in an approximate 48*F drop in feedwater temperature. The limit for this test was a 100 F reduction. Core thermal power increased to 91%.

Power % 8 Ave Feedwater Temp F 415 367 MCPR 1.;727 1.668 CMFCP .706 .731 CMFLPD .745 .817 CMAPR .721 .790 Acceptance criter,ia were satisfie STP-23.5 "Feedwater Pump Trip", Revision 0, test implemented January 22, 198 With the reactor at 96.7% power the C~ reactor feedwater pump was tripped. Reactor water level dropped about 8 inches when the l

recirculation pumps automatically reduced power to be within the capability of the operating feedwater pumps. Acceptance cri-teria were satisfie STP-23.7 " Maximum Feedwater Runout Capability", Revision 1, test implemented January 21, 198 The test demonstrated by use of test data and pump head flow curves that the total feedwater runout at 1060 psig reactor pressure was less than 19.07 MLB/HR and the runout at 1005 psig reactor pressure was less than 20.63 MLB/HR.

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STP-24.1 "Stop Valve Testing", Revision 0, test implemented December 29, 1985 and December 31, 198 Test was performed at 79.5% and 92% power. Acceptance criteria were satisfie STP-24.2 " Control Valve Testing", Revision 0, test implemented December 28 and December 31, 198 The test was performed at 78.4% and 89.2% power. Acceptance criteria were satisfie STP-24.3 " Bypass Valve Testing", Revision 0, test implemented December 31, 198 This test was performed at 95% power. Acceptance criteria were satisfie STP-25.2 " Full Closure of Fattest MSIV", Revision 0, test implemented Januari 1, 198 This test was performed with the reactor at 75% power. MSIV stroke time was 3.49 seconds thus satisfying the acceptance criteri STP-25.3 " Full MSIV Closure", Revisi 1, test implemented December 18, 198 ,

The test was performed at 91.6% power SIV c sure was demanded by simulating low steam line p hen in the RUN mode. MSIV stroke times satisfied test cri .ria. Criteria on heat flux and pressure increase were satisfied. The inspector also reviewed safety _ evaluation 85-0786 dated January 31, 1986 to justify performing the test at 91.6% power rather than in the TC-6 test windo The safety evaluation was considered acceptable. Actual test data was compared to predictions of the test from the actual initial conditions and extrapolated to 100% powe STP-27.4 " Turbine Trip at TC-6", Revision 1, test implemented January 2, 198 This test was initiated from 98.9% power. Acceptance criteria for the turbine bypass valve response, recirculation pump coast- ,

down and maximum permissible pressure rise were satisfied. The '

pressure increase was 114 psid with a maximum limit of 139 psi The minimum water level reached was 2.4 inches and the feedwater control system quickly restored the level. A test exception on

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feedwater was prepared, however, due to water level exceeding 54 inches (60 inches measured) and requiring a feedwater pump tri The RPS response was acceptable based on review of the se-quence of events lo '

STP-29.2 " Master Manual Recirc Flow Control", Revision 0, test implemented December 29, 198 This test was initiated from 95.9% core flow and 98.9% core thermal power. No unacceptable oscillations were noted during the step changes in recirculation speed STP-30.1 " Recirculation System, One Pump Trip", Revision 1, test implemented January 22, 198 The reactor did not scram during the one pump recirculation {

pump trip as expected. However, reactor level did not satisfy l the minimum margin specified to preclude a high level turbine '

trip. A test exception was identifie STP-30.3 " Recirculation System Performance", Revision 1, test imple-mented December 26, 198 Acceptance criteria were satisfie STP-32.1 " Primary Containment Temperature", Revision 1, test implemented December 30, 198 With the reactor at 98.5% power, The average drywell temperature was 127*F satisfying the acceptance criteria of less than 135* STP-32.2 " Hot Penetration Concrete Temperature", Revision 0, test implemented December 30, 198 With the reactor at 98.5% power the containment penetration surrounding temperature satisfied the test criteri STP-33.1 " Main Steam Piping (Inside Drywell) Steady State Vibration", Revision 0, test implemented December 27, 198 .With steam flows at 100%, vibration levels were acceptabl STP-33.2 " Recirculation Piping Steady State Vibration", Revision 1, test implemented December 27, 198 With recirculation flow at 100%, vibration levels were acceptabl _

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STP-33.3 " Main Steam /0utside Drywell Main Steam Bypass an Feedwater Piping Steady State Vibration", Revision 1, test imple-mented January 23, 198 With the reactor at 100% power, no unacceptable vibration levels were note STP-34.1 "Off Gas Performance Verification", Revision 2, test implemented January 2, 198 This test was performed at 97.9% power. Off gas performance was acceptabl STP-35.1 " Recirculation System Flow Calibration", Revision 0, test implemented January 24, 198 Recirculation system flows were calibrated within the acceptance criteria specifie .STP-35.2 " Recirculation System Flow limiter Adjustment", Revision 0, test implemented December 26 198 The Recirculation' pump electrical limiters were set less than 102.5% of rated flo Speed Set Limit rpm A 972 <981 B 974 <976 STP-36.1 " Main Steam Piping Vibration During Main Turbine Stop-Valve and Control Valve Closures", Revision 0, test implemented January 2, 198 This data was taken in conjunction with the turbine trip during TC-6. Vibration levels were generally acceptable, however, test exceptions on vibration levels were identified for additional analysi STP-36.3 " Recirculation Piping Vibration During Recirc. Pump Trip and Restart", Revision 0, test implemented January 22, 198 Vibration levels were acceptable during both evolution STP-36.5 "Feedwater Piping Vibration During Feedwater Pump Trip",

Revision 1, test ' implemented January 22, 198 Vibration levels were acceptabl #

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STP-71.4 " Shutdown Cooling Mode", Revision 0, test implemented January.3, 198 The A and B RHR heat exchangers were verified to satisfy the acceptance criteri The following TC-6 Test Results were only reviewed for acceptance by Management:

STP- " Gaseous Effluent Sampling and Analysis", Revision 0, test

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implemented January 2, 198 STP- " Sample Station Operability", Revision 0, test impleniented January 27, 198 STP- " Reference Leg Temperature Comparison", Revision 1, test implemented December 26, 198 STP-13.7 " Data Transmittal", Revision 0, test implemented January 1, 198 STP-13.9 " Program Testing During Power Changes", Revision 2, test implemented December 10, 198 STP-13.10 "PCIOMR Testing", Revision 0, test implemented January 10, 198 During the warranty run the licensee discovered a 1% error in the feedwater flow transmitters and among other actions did an assessment of the impact of this IL error on the startup tests. The licensee documented their assessment in GE-SM-258 dated February 13, 198 The conclusion of the evaluation was that the error was well within the accuracy and acceptance criteria of the startup tests. The in-spector review of the test results also concluded that the 1% error had no impact on the conclusions drawn from the test data and that reperformance of APRM calibrations performed after calibration of the feedwater flow transmitted satisfied inspector concern Findings No violations were identifie .2 Test Exceptions Scope The inspector reviewed 80 cicsed test exceptions for technical adequacy and being processed in accordance with the administrative procedure. The inspector also reviewed the 32 open test exceptions

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-that still remain open following the completion of the startup test program to verify that the licensee plans for closure were appropri-ate and that an adequate tracking mechanism exist Discussion The test exceptions closed were considered acceptable. The open test exceptions do have satisfactory action plans and are being acceptably tracke The licensee is using the PORC Heeting minutes to assure.that the open test exceptions are being resolved. PORC reviews the status at least bi-weekly and will, in addition to the test exception report form, document the disposition of the test exception. While at the conclusion of this inspection 32 test exception reports remain open-they can be grouped into several categories. The most significant test exception category (30%) related to the feedwater control system response. The feedwater control system tends to overfill the reactor vessel on rapid level changes. The licensee has evaluated that the feedwater control system is operationally acceptable but not optimized and the action plan will perform additional tuning following the next reactor shutdown. The recirculation flow control response accounts for about 15% of the test exceptions with concerns-limited to certain power to flow regions which can be operationally avoided. Approximately 25% of the test exceptions deal with area temperature limits. Whereas technical specification limits are not impacted, expected performance values are exceede The remainder are for miscellaneous' areas including administrative controls to assure testing which can only be performed while the plant is shut-down is obtained at the next shutdown and cooldown. The licensee actions relating to the open test exceptions were found to be ac-ceptabl Findings No violations were observe .3 Plateau Review The inspector reviewed STP-99.6 " Test Plateau D 100% Rod Line Testing", Revision 1, dated January 31, 1986 and PORC Meeting Minutes 86-15 dated January 31, 1986 and determined that the licensee actions to review the 100% rod line testing were acceptable. The open test exceptions were reviewed and are being tracked via PORC meeting minute No unacceptable conditions were note ' *

2.4 Overall Program During this inspection the inspector held discussions with the Assistant Operations Engineer on the implementation of the lessons learned during performance of the remote shutdown demonstration startup test. Previous inspection 50-352/85-38 reviewed the licensee plans. The licensee has implemented the lessons learned into procedure revision and/or plans for hardware changes. P&ID's have been added to the remote shutdown panel and MOD 794 is planned

.to add additional communication features. The remote' shutdown panel has operator aids to assist in determining narrow range level readings based on observed wide range levels as reactor pressure is reduced. The licensee had determi.ned the type of keys needed in the remote shutdown area and will install them in the are This inspection completes the NRC Region I Region-based inspection of the Limerick Unit 1 Startup Test Program. The licensee actions were determined'to be appropriate with' adequate controls and plans developed to close out the open test exceptions still outstandin .0 QA/QC Interfaces for Startup The inspector assessed that QC review of completed startup test results had been performed as required per the administrative procedure. The inspector reviewed a draft of the QA audit report AL85-111PR of the TC-4,

.5 and 6 Startup testing. QA had identified followup items for them to assure FSAR revisions were assessed and that the open items after the completion of the startup testing were properly closed out. No unaccep-table conditions were noted in the QA/QC interfaces with startu .0- Independent Measurements, Calculations & Verifications During this inspection, the inspector verified several of the analysis steps in completed test procedures using the data collected during the test as part of the test results evaluatio .0 Exit Interview An exit meeting was held on February 28, 1986 to discuss the inspection findings as detailed in this report (see paragraph one for attendees).

At no time during the inspection did the inspector provide written in-spection findings to the licensee. At the exit, the licensee did not identify any proprietary material that was contained within the scope of the inspectio a