IR 05000352/1986016

Insp Rept 50-352/86-16 on 860707-11.No Violations or Deviations Noted.Major Areas Inspected:Tech Spec Surveillance Testing & Calibr Program,Calibr of safety- Related Instruments & Test Equipment Control Program

ML20203E023
Person / Time
Site:	Limerick
Issue date:	07/18/1986
From:	Chaudhary S, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20203D990	List: IR 05000352/1986016 ML20203D987
References
50-352-86-16, NUDOCS 8607240041
Download: ML20203E023 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-16 Docket N License N NPF-39 Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Limerick Generating Station, Unit-1 Inspection At: Limerick, PA Inspection Conducted: July 7-11, 1986 Inspectors: .

S.K. Cha ft ary, Lead Reactor Engineer h j /[ //[I dat'e Approved by: (M k-J. Johnson, Chief, Operational Programs h/#/"

date Section, 08, DRS Inspection Summary: Inspection on July 7-11, 1986 (Report No. 50-352/86-16)

Areas Inspected: A routine unannounced inspection by one region-based in-spector of the Technical Specification surveillance testing and calibration program; calibration of safety-related instruments; and the measuring and test equipment control progra Results: No violations or deviations were identifie PDR ADOCK 05000352 G PDR

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DETAILS Persons Contacted Philadelphia Electric Company

• J. Brittan, Test Engineer-Surveillance Test Coordinator E. Calla, I&C Engineer

• • P. J. Duca, Technical Engineer

• G. D. Edwards, Performance Engineer C. R. Endriss, Regulatory Engineer

• J. F. Franz, Manager J. Grimes, T&L Engineer

• J. Rubert, QA Site Supervisor J. J. McElwain, Auditor, EPQA

• V. A. Warren, Test Engineer-Regulatory US Nuclear Regulatory Commission E. Kelly, Senior Resident Inspector

• S. Kucharski, Resident Inspector In addition to the above, the inspector contacted, and held discussions with other licensee personnel (including angineers, supervisors, and QA/QC personnel) during the course of this insp tio * indicates those present at the main exit meeting held on July 10, 198 ** indicates the person with whom the inspector had an additional exit meet-ing on July 11, 198 . Surveillance Testing and Calibration Control Program The inspector reviewed documentation to ascertain whether the licensee had developed and effectively implemented programs for surveillance testing, calibration, and inspections required by section 4 of the plant Technical Specification (TS). The program for calibration of other safety-related '

instrumentation, not covered by TS, was also examined for adequacy and effectiveness. The inspector interviewed and held discussions with li-censee personnel and cognizant plant management to assess their knowledge and understanding of the program requirements, and to review responsi-bilities assigned to various departments and sections of the licensee's organizatio .

. 3 2.1 Program Review The inspector reviewed the licensee's management controls for Sur-veillance Test and Calibration (ST) program. The ST program is man-aged and controlled by a computer program called Surveillance Test And Records System (STARS). This computte system is used to store and track instrument calibration and surveillance test informatio This information includes the last date that a ST was performed, the date of the next scheduled surveillance, whether the scheduled date has been met, and the base number of days between tests and calib-ratio The inspector verified that access to the program is controlled by the surveillance test coordinator (STC), who alone possessed the program access code. The STC is responsible for entering data into the syste The computer program has several features which minimize the possibility of introducing mistakes while entering data that would be carried into the next calibration period. Spot checks are also performed periodically by the I&C department as well as formal audits by Quality Assurance. These audits further ensure that cali-bration frequencies and other data are correct as stated on the com-puter program output The inspector also verified a change to the computer program which involved a proposed TS change and the associated calibration fre-quency change that would need to be reflected in the ST program. The program was then initiated to calculate the next calibration date, the inspector verified that the new calculated dates were correc .2 Findings Based on the above review, examination, and discussions with cogni-zant personnel, the inspector determined that: A master schedule for TS calibration and functional testing of instrumentation and systems was established; the schedule in-cluded frequency of each test / calibration and/or inspection, the responsibility for implementation, and the surveillance test /

calibration status of the item or syste . The responsibility for maintaining and up-dating the schedule was established and assigned by procedur . The current master schedule reflected the TS requirements for such tests and/or calibration, and The responsibilities for review and evaluation of data, report-ing and controlling deficiencies, and ensuring the required surveillance test / calibration was satisfied had been established by procedure .

. 4 The inspector had no further questions in this area. No vio-lations were identifie . Calibration of Safety-Related Components Not Covered by Technical Specification The inspector reviewed the program description and examined records to determine if calibration requirements had been established for components associated with safety-related systems and/or functions, but that were not specified in the TS and if a master schedule had been developed that included calibration frequency, responsibility for implementation, and the calibration status of each componen The inspector determined that a calibration program had been established for such safety-related components. A master schedule had been developed to show the responsibility, frequency, and the status of calibration for each safety-related component not covered by the Technical Specification, as well as to ensure adequate records were maintaine No violations were identifie . Surveillance Procedure and Records The inspector reivewed procedures and records to verify that surveillance of safety-related systems and components was being conducted in accordance with approved procedures as required by TS; and also if these procedures were adequate to accomplish the safety intent of the TS requirement, thus ,

assuring operational safety of the plan The inspector selected at least two tests from each of the following areas to verify the adequacy of conformance to the above requirement The tests were randomly selected from the master schedule for surveillance test Documents reviewed are listed in section 8 of this repor Areas included were:

Reactivity Control and Power Distribution,

Reactor Coolant System,

Emergency Core Cooling System,

Containment System,

Plant Electrical Power System, and

Intrumentation 4.1 Findings Based on the above review and examinations, the inspector determined that the procedures were adequate to direct and control surveillance testin Procedures included required prerequisites and preparations for test; acceptance criteria; instructions and steps to assure that the system or components were restored to an operating condition after the test; and responsibilities for review and approval for the test dat Procedures appeared to meet the intent of the TS surveillance testing requirements.

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. 5 The inspector also determined that the records maintained for these tests were adequate. They showed that the completed tests were reviewed for acceptability of results; met the testing frequency; and were in confor-mance with the TS requirements for the surveillance / test No violations were identifie . Quality Assurance Program for Measuring and Test Equipment The inspector reviewed the licensee's QA program to ascertain if the program adequately provided administrative controls over measuring and test equipment (M&TE); and if the controls provided were in conformance with regulatory requirements, commitments, and industry standard The program review consisted of verification of licensee's commitments in the Final Safety Analysis Report (FSAR) for conformance with regulatory requirements, and review of procedures for adequacy. The inspector de-termined that the licensee's commitments in the FSAR were generally ade-quate to fulfill regulatory requirement The procedures contained criteria and responsibilities for calibration frequency, methods for plac-ing in or removing equipment from service, and the calibration status of the equipmen The procedures also included methods of documenting calibration history of equipment, including:

Traceability to calibration source,

As-found and as-calibrated data, Identification of standards used,

Identification of calibration procedure used, and its traceability to a national standard,

Date of calibration, and

Name of person performing calibratio The procedure also specified that M&TE equipment must have accuracy four times greater than the equipment which was being calibrated. A system, very similar to the master schedule used for TS calibration, was in use for controlling the calibration frequency and recall of equipment. Re-quirements for the history of use, and controls to prevent inadvertent use of equipment beyond calibration frequency were also established. The procedure also required an investigation and evaluation of data recorded by the M&TE prior to scheduled calibration if the M&T Equipment was found

. to be out of calibration. The inspector also questioned the responsible I&C supervisor to assess his knowledge and understanding of the program, and found him to be knowledgeable.

i No violations were identified.

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. 6 Quality Assurance (QA) Department Involvement in Surveillance / Calibration Program The inspector examined documents, and held discussions with QA supervisors and cognizant personnel to assess the understanding of their responsibi-lities in this area, and their involvement in the implementation of this

progra Based on the above discussions and the examination of QA records, the inspector determined that the plant QA department performed planned struc-tured program audits. Additionally, QA personnel perform surveillance inspections routinely. The surveillance inspections are not comprehen-sive, structured inspections, but are limited scope inspections covering individual items, activities or a small part of the program. These sur-veillance inspections are designed to verify the overall implementation of

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calibration and TS surveillance test progra Based on the above examination and discussions, the inspector determined that Quality Assurance management and staff were aware of their respons-ibilities; the planned audits were comprehensive, and were well documen-te No violations were identified.

' Management Meeting At the conclusion of the inspection, the inspector met with licensee

! management (identified in paragraph I with a *), at which time the in-spectors summarized the purpose, scope, and the findings of the inspec-l tion. The licensee acknowledged the inspectors' finding At no time during this inspection, did inspectors provide written material

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to the license . Documents Reviewed / Audited l

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Final Safety Analysis Report, Chapter 1 LGS Technical Specification; Section 4, " Surveillance Tests".

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Administrative Procedure A-43; " Surveillance Testing Program". Re , Effective March 6, 198 Administrative Procedure A-47; " Procedure for Preparation and Control

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of Surveillance Test Procedures". Rev. 5, Effective March 6, 1986.

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Administrative Procedure TL-12-50008; "Use and Control of Calibration of Measuring and Test Equipment", Rev. 2.

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QA Department Procedures:

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QADP-5; " Procedures for Performance of QA Division Audits". Re .

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QADP-G; " Quality Assurance Division Audit Program". Rev. 1 QADP-8; " Procedures for Preparation and Use of Audit Check Lists", Rev. QADP-9; " Procedure for Control of Findings". Rev. 1 QAD-12; " Procedure for Performance of QA Division Surveil-lances". Rev. 1 QAD-Operations Phase Audit AL85-76-ST; " LGS Surveillance Test Program".

AL85-116-S0; " Full Power Limiting Co.1dition For Operation, Unit-1".

AL85-85-PR; " Start-up Test Program, Plateau C, Test Condition 3".

AL85-64-50; " Unit-1 Start-up LCOs".

AL85-01-PR; " Start-up Program".

AL85-40-H0; " LGS-Liquid / Gaseous Effluent Release".

QA Division Surveillance Reports:

LMR-R -0687; LMR-86-0688 l LMR-86-093; LMR-86-0694

LMR-86-0711

LMR-86-0710 LMR-86-0763; LMR-86-0785 ( LMR-86-0655; u'9-86-0658 LMR-86-0659; LMK-86-0660 LMR-86-0668; LMR-86-0671 LMR-86-0672; Surveillance Tests and Procedures:

K-Test # ST-3-107-790-1, " Control Rod Scram Timing".

l I K-Test # ST-6-060-460-1, " Primary containment Isolation Capability

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K-Test # ST-6-060-470-1, " Primary Containment Airlock Door Interlock

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Test # ST-6-107-590-1; Stand-by Liquid Control Syste Test # ST-2-026-617-1; Reactor Coolant Syste Test # ST-6-107-590-1; Leak Detection System.

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Test # ST-6-052-832-1; ECCS.

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Test # ST-6-107-451-1; ECC Test # ST-6-107-594-1; AC - Power System.

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Test # ST-8-036-621-1; Power System.

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