IR 05000352/1986018

Insp Rept 50-352/86-18 on 860801-0915.No Violations Identified.Major Areas Inspected:Followup on Outstanding Items,Sys Walkdown of Selected Sys Using PRA Guidance,Plant Tours,Maint Observations & Review of LERs & Periodic Repts

ML20215M786
Person / Time
Site:	Limerick
Issue date:	10/17/1986
From:	Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20215M778	List: IR 05000352/1986018 ML20215M777
References
50-352-86-18, NUDOCS 8611030293
Download: ML20215M786 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-18 Docket N License N NPF-39 Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility: Limerick Generating Station, Unit 1 Inspection Periods: August 1 - September 15, 1986 Inspectors: E. M. Kelly, Senior Resident Inspector S. D. Kucharski, Resident Inspecto C. Gordon, Emergency Preparedness Specialist R. Winters, Reactor Engineer C. Conklin, Emergency Preparedness Specialist Approved by: /4 - /7- 84 Peter Esel h, Chief, Projects date Section Summary: Routine daytime and backshift inspections (211 hours0.00244 days <br />0.0586 hours <br />3.488757e-4 weeks <br />8.02855e-5 months <br />) of Unit I by the Resident Inspectors and Region I specialists consisting of followup on outstanding items; system walkdown of selected systems using PRA guidance; plant tours; maintenance observations; and review of LERs periodic reports, and events which occurred during the perio No violations were identified, and no unresolved or followup items were initiate PDR ADOCK 05000352 O PDR

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l 1.0 Principals Contacted  !

1.1 Philadelphia Electric Company J. Corcoran, Engineer-In Charge, Field QA J. Doering, Superintendent of Operations R. Dubiel, Senior Health Physicist P. Duca, Technical Engineer J. Franz, Station Manager J. Milito, Field Engineering Supervisor R. Moore, QA Division Superintendent J. Spencer, Superintendent of Plant Services M. Roache, Site Emergency Preparedness Coordinator Also during this inspection period, the inspectors discussed plant status and operations with other supervisors and engineers in the PECO, Bechtel and General Electric organization .0 Followup on Unresolved Items 2.1 (Closed) Unresolved Item 86-07-01 Licensee Medical Emergency Drill Region I Emergency Preparedness staff observed a drill on August 12, 1986 which tested emergency response by Search and Rescue and F'rst Aid teams to a simulated contaminated / injured individual in the reactor building. During the April 3, 1986 emergency exercise, NRC inspectors had observed that the first aid group quickly responded to the medical emergency. However, it took over 10 minutes before any medical attention was given to the victim. An attempt was made to stop the bleeding from a simulated compound fracture, but initially no vital signs were taken even though the victim was pale and appeared to be in shock. The observer later noted that it had taken over an hour before the victim was brought to the ambulanc In response to the NRC inspection team concerns, a repeat drill was conducted on August 12, 1986. The inspectors observed that immediate actions taken by emergency personnel were in accordance with emergency procedure EP-252 and provided prompt medical attention was provided to the patien Followup medical and decontamination activities demonstrated by site and hospital personnel were also adequately performed. This was evident at the accident scene and while moving the victim to a temporary treatment area, then to Montgomery Hospital in Norristown via ambulance. This item is close r

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2.2 (Closed) Bulletin (79-BU-3A) longitudinal Weld Defects in ASME SA-312 Type 304 Stainless Steel Pipe The inspector verified that the licensee has reviewed the wall thickness calculations for longitudinal welds in SA-312 seam welded pipe and determined, based on minimum wall thickness, that none of this pipe used in safety related systems in units 1 and 2 is subject to stresses greater than 85% of the code allowable stress. This item therefore is close .3 (Closed) Inspector Followup Item (85-16-03) Licensee to Implement an 18-month Functional Test Program for Fire Dampers The inspector reviewed surveillance test procedure ST-7-022-921, Fire Damper Inspection, Revision 1, May 16, 1986. The li.censee has incorporated into this procedure a program to implement an 18 month functional test for fire dampers. The program directs a technician to perform a functional test on.each damper, if able, barring any safety or HP concerns. In addition, it details how to perform the functional test based on the type of damper. The inspector had no

- further concerns. Therefore this item is considered close .0 Review of Plant Operations 3.1 Summary of Events The plant operated at full rated power throughout the inspection

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perio .2 Operational Safety Verification The inspector toured the control room daily to verify proper manning, access control, adherence to approved procedures, and compliance with LCOs. Instrumentation and recorder traces were observed and the status of control room annunciators was reviewe Nuclear instrument panels and other reactor protective systems were examine Effluent monitors were reviewed for indications of release Panel indications for onsite/offsite emergency power sources were examined for automatic operability. During entry to and egress from the protected area and vital island, the inspector observed access control, security boundary integrity, search activities, escorting and badging, and availability of radiation monitoring equipment including portal monitors. No unacceptable conditions were note The inspector reviewed shift superintendent, control room supervisor, and operator logs covering the entire inspection perio Sampling reviews were made of equipment trouble tags, night orders, and the temporary circuit alteration and LCO tracking logs. The inspector also observed shift turnovers during the period. In

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addition, operations activities were observed for conformance with the applicable procedures and requirements. No unacceptable conditions were note .3 Station Tours The inspection toured accessible areas of the plant throughout this inspection period, including: the unit I reactor and turbine-auxiliary enclosures; the main control and auxiliary equipment rooms; emergency switch gear and cable spreading rooms, and the plant site parameter. During these tours, observations were made relative to equipment condition, fire hazards, fire protection, adherence to procedure, radiological controls and conditions, housekeeping, security, tagging of equipment, ongoing maintenance and surveillance and availability of redundant equipment. No unacceptable conditions were note .4 System Walkdown 3. Engineered Safeguards Features (ESF) System Walkdown The inspector performed a detailed.walkdown of portions of the RCIC, HPCI, and RHR Systems in order to independently verify their operability. The walkdowns included verifications of the following items:

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Review of Technical Specification, the FSAR System operating procedures and P&ID's

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Inspector of system equipment conditions

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System check-off-list (COL) and operating procedures consistent with plant drawings

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Valves, breakers, and switches properly aligned, including appropriate locking devices

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Instrumentation properly valved in and operable

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Satisfactory control room switches, indicators and controls Within the scope of the walkdown, no unacceptable conditions were note F

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4.0 Licensee Reports 4.1 In-Office Review of Licensee Event Reports The inspector reviewed Unit 1 LERs submitted to the NRC Region I office to verify that details of the event were clearly reported, including the accuracy of description of the cause an adequacy of corrective action. The inspector determined whether further information was required from the licensee, whether generic implications were involved, and whether the event warranted on-site followup. The following LERs were reviewed:

LER NUMBER REPORT DATE SUBJECT 86-033 August 1 Reactor Water Cleanup System Isolation on High Differential Flow 86-034 August 1 Open Fire Door Without a Posted Firewatch Due to Personnel Error 86-035 August 6 Failure to Comply with Technical Specification Action Due to Procedural Deficiency 86-036 August 7 Failure to Perform Hourly Fire Watch Required by Technical Specifications86-037 August 8 Control Room Emergency Fresh Air (Note A) System Actuation Due to Presence of Chlorine 86-038 August 6 Primary Containment Isolation Valves Inoperable with Penetration Open 86-039 August 20 Main Control Room Chlorine Isolations (Note A) & Emergency Fresh Air System Actuations86-040 August 25 Reactor Water Cleanup System (Note A) Isolations Due to High Regenerative Heat Exchanger Room Temperature 86-041 September 5 Technical Specification Violation Resulting from Deficient Surveillance Test 85-102 August 20 Excessive Leakage of Containment Spray Valve, HV-51-1F016A Notes: -

A: Addressed in Detail 4.2 of this repor .

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4.2 Onsite Followup of Licensee Event Reports For those LERs selected for onsite followup as noted in Section 4.1, the inspector verified the reporting requirements of 10 CFR 50.73 and technical specifications had been met, that appropriate corrective action had been taken, that the event was reviewed by the licensee, and that continued operation of tl.e facility was conducted in accordance with Technical Specification limit . LER 86-037 Control Room Emergency Fresh Air System Actuation Due to Presence of Chlorine On July 9, 1986, with the Unit in Operating Condition 4 (Cold Shutdown) at 0% power, the main control room ventilation system isolated and the Control Room Emergency Fresh Air System (CREFAS) started. The 'C' and 'D'

Chlorine Analyzers, which function to isolate the control room ventilation system, indicated that low chlorine concentrations were present in the control room ventilation intake air. The concentration levels were and 1.5 parts per million (ppm) for approximately 5 minute The event occurred as a result of chlorination of the water in the Unit 1 Cooling Tower basin. The chlorination

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process started during a severe rainstorm which had high winds. It is suspected, by the licensee, that chlorine was transported by the wind into the Control Enclosure HVAC intake plenum causing the alarm and eventually the isolatio This event was reviewed by the inspector and the licensee and concluded that it had occurred from an unusual combination of weather conditions concurrent with chlorination of the cooling tower basin. The chlorine analyzers, control room ventilation, and CREFAS responded as designed. The levels of chlorine present at the intake plenum were low and of short duration, causing no hazard to personnel. The inspector had no further question . LER 86-039 Main Control Room Chlorine Isolations and Emergency Fresh Air System Actuation Between July 21, 1986 and July 24, 1986, with the unit in Operating Mode 1 (OPCON 1) at 100% power, there were three events where the main control room ventilation system '

isolated and the Control Room Emergency Fresh Air System (CREFAS) automatically started.

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y On July 21, 1986, the 'C' Chlorine channel actuated, causing the Main Control Room ventilation system to isolate and the 'A' train of the CREFAS to start. The remaining three chlorine detectors showed normal readings. The three remaining channels were manually initiated in accordance with system procedure S78.8.A,

" Manual Initiation of Control Room Radiation or Chlorine / Toxic Chemical Isolation" and the isolation of all four channels were verified in accordance with system procedure S78.0.8, " Verification of Control Room HVAC Response to a Control Room Isolation Signal".

Investigation by the licensee discovered a piece of debris on the wick of the Chlorine Analyzer probe, causing the probe to malfunction. The probe was removed, cleaned, reinstalled and calibrated according to the following procedures:

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ST-5-078-349-0; Adding Electrolyte to Anacon Chlorine Probe (AE-78-016C), Revision 1, June 24, 198 ST-2-078-406-0; Chlorine Detection System - Control Enclosures Air Intake Chlorine Detector, Channel C Calibration / Functional Test (AITS-78-016C, AI-78-016C), Revision 1, May 20, 198 ST-5-078-609-0; Anacon Chlorine Probe Replacement and Functional Test (AE-78-016C), Revision 1, July 7, 198 An orange discoloration was discovered on the wick where the debris was located. On July 22, the 'C' Channel Main Control Room isolation signal occurred again as a result of a false signal. The probe was replaced with a new probe. On July 24, 1986, another 'C' Channel Main Control Room isolation signal occurred. The Chlorine Analyzer was removed from service and investigation showed a yellowish-orange discoloration on the prob The resident witnessed the events that had occurred and held interviews with the technicians involved. It was discovered that the normal installation of a new probe, no electrolyte solution is added, since the probe is shipped by the manufacturer in the solutio However, some replacement probes do not have enough solution which results in probe malfunction. To prevent reoccurrences the licensee will now add electrolyte solution to newly installed probes as a preventive measur The inspector had no further question *

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4. LER 86-040 Reactor Water Cleanup System Isolations Due to High Regenerative Heat Exchanger Room Temperature On July 23, 1986, with the unit in operating condition 1 (OPCON 1) at 99.8% power, the Reactor Water Cleanup (RWCU)

system isolated twice as a result of regenerative heat exchanger room temperature exceeding the 122 degree fahrenheit isolation setpoint. The first room high temperature alarm resulted from the Reactor Enclosure Ventilation System being removed from service in order to perform maintenance work on the Reactor Enclosure supply cooling coils which resulted in adequate room ventilatio Following the return to service of the Reactor Enclosure Ventilation System, a second automatic isolation resulted. This second isolation resulted from the failure of pressure relief valve, PSV-44-109, which had opened at a pressure below setpoint, releasing steam into the room. The malfunctioning valve was removed and a blank flange temporarily installed in its place. To assure that a safety relief valve downstream of the failed valve would provide adequate relief for the system if needed, the licensee blocked open two series inlet valves for the 'A'

non-regenerative heat exchange The inspector reviewed the corrective actions and held discussions with the licensee about preventative actions taken. The licensee has revised the following procedures:

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S76.8.B, Manual Initiation of Reactor Enclosure or Refueling Floor Secondary Containment Isolation

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S76.2.B, Shutdown of Reactor Enclosure HVAC to include a precaution which states that when the Reactor Enclosure Ventilation System is not in service the RWCU system will isolate when the regenerative heat exchanger room temperature exceeds the high setpoint (122F). In addition, Annunciator Response and ARC-MCR-004 was revised to assure RWCU room temperature are monitored when the Reactor Enclosure HVAC is shutdown.

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The inspector had no further question .3 Review of Periodic and Special Reports Upon receipt, periodic or special reports submitted by the licensee were reviewed by the inspector. The reports were reviewed to determine that the report included all

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required information, that test results and/or supporting information were consistent with design predictions and performance specifications, and whether any information in the report should be classified as an abnormal occurrence.

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The following periodic and special reports were reviewed:

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Monthly Operating Report for July 1986 This report was found to be acceptabl .0 Maintenance Activities 5.1 Maintenance on Pressure Relief Valve PSV-44-109 During this inspection period the licensee perforned maintenance on the pressure relief valve, PSV-44-109, due to premature lifting which resulted in a RWCU isolation (See section 4.2.3 for details). On July 24, the pressure relief valve was removed from service, a blank flange was installed and the system was returned to servic The inspector reviewed the maintenance request form package (MRF

1. 8604707) which included the vendor's manual, for " Instructions for installing, adjusting and dismantling of LCT series relief valves",

Manual #69 and Installation and Maintenance, Manual #81. The inspector witnessed the technicians involvement in repairing the seat and disc

- assembly. The personnel involved in the effort were knowledgeable but were not able to repair the surfaces of the seat and disc due to the condition of the seating. surfaces. The licensee will therefore install a new valve during the next outage. The method for operating the system in this temporary condition, as defined in Section 4. is acceptable. The inspector had no further concern .0 Surveillance Activities The inspector observed performance of, or reviewed the results of, the following tests:

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ST-1-052-102-1, Loop 'B' Core Spray LSF/SAA Test, Revision 2, May 3, 1986 ST-1-052-802-1, Loop 'B' Core Spray System Response Time Test, Revision 4, April 3, 1986 ST-1-052-852-1, Loop 'B' Core Spray Initiation Response Time Summation, Revision 3, January 28, 1985 The tests were observed to determine that test procedures conformed to Technical Specification requirements; proper administrative controls and tagouts were obtained prior to testing; testing was performed by qualified personnel in accordance with approved procedures and calibrated instrumentation; test data and results were accurate and in accordance with Technical Specifications; and, equipment was properly returned to service following testin No unacceptable conditions were note ', .

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7.0 Radwaste Operations During this inspection period the inspector reviewed the radwaste operation, particularly the removal of resins from the Reactor Water Cleanup (RWCU) demineralizers. The process involves transfer of the radwaste resin from the demineralizer by a back washing method to the back-wash receiving tank. Once in the back-wash receiving tank, air pressure is introduced to decrease the size of any large chunks of resin that may exist, by an ' Air-Fluff' process. The resin is than released from the back-wash receiving tank to the phase separation tank by gravity flow, where the water is removed and the resin is pumped to storage tanks for remova During the review process, the inspector noted, on April 9, 1986, that the resin had to be removed by hand from the phase separator tank due to the clogging of the sparger nozzles by paint chips. Since the phase separator tank is a collection point for other sources of sludge / resin it is suspected that the chips came from the drain tanks. The blockage affected operation of the sludge discharge mixing pump and necessitated emptying of the tank contents to access, clean and replace the sparger nozzles. The work was performed under authorization of an RWP and in accordance with an approved procedure developed to educt sludge / resin out of the phase separator and into 55 gallon drums using a portable pum Appropriate training was provided to the radwaste technicians for the removal process. The inspector had no further question .0 Exit Meeting The NRC resident inspector discussed the issues in this report throughout the inspection period, and summarized the findings at an exit meeting held with Mr. John Franz and others of your staff on September 15, 198 At this meeting, the licensee's representatives indicated that the items discussed in this report did not involve proprietary informatio l

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