IR 05000352/1987019

Operational Readings Team Insp Rept 50-352/87-19 on 870817- 21.Violations Noted.Major Areas Inspected:Plant Operations, Maint,Surveillance Testing,Plant Mods & Readiness for Plant to Resume Operations Following Outage

ML20235W931
Person / Time
Site:	Limerick
Issue date:	10/06/1987
From:	Borchardt R, Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235W879	List: IR 05000352/1987019 ML20235W877 ML20235W880
References
50-352-87-19, NUDOCS 8710190102
Download: ML20235W931 (18)

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Appendix A 3 U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-19 Docket N l License N NPF-27 i Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Limerick Generating Station, Unit 1 Inspection At: Limerick, Pennsylvania Inspection Conducted: August 17 - August 21, 1987 Inspectors: R. Borchardt, Senior Resident Inspector J. Wechselberger, Resident Inspector S. Kucharski, Resident Inspector J. Lyash, Resident Inspector L. Scholl, Reactor Engineer ea e d r: _ ._1 d Y 0 7 R. Borch dt, r Resident Inspector ate Approved by: _/ ~_/3 _. Linvi fle, ~-i f, Section 2A, Division

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Da t'e Reactor Pr ts Inspection Summary: Inspection 50-352/87-19 on August 17 - August 21, 198 Areas Inspected: The Operational Readiness Team inspection reviewed activities in the areas of plant operations, maintenance, surveillance testing, and plant modifications. The inspection was primarily directed toward determining the overall readiness for the plant to resume oower operations following the completion of the first refueling outage. The inspection war performed by four resident inspectors and one Region based inspecto This in.pection consisted of 195.5 inspection hour h[[ O 00 2

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TABLE OF CONTENTS i' Pag l'. 0 Persons Contacted. . . . . . . . . . . . . . . . . . . . . . 2

' 2.0 Inspection Summary: Strengths and Weaknesses. . . . . . . . 2 3.0- Purpose and Scope. . . . . . . . . . . . . . . . .. . . . . . 4 i

4.0 Plant Modifications i 4.1 Summary of Plant Modifications Inspected. . . . . . . . 5 4.2 Inspection Results. . . . . . . . . . . . . . . . . . . G 5.0 Maintenance and Surveillance 5.1 Maintenance Program . ............... .. 7 . 5.2 Surveillance-Testing. . . . . . ............ 8 l 6.0 Conduct of Operations. . . . . . . . . . . . . . . . . . . . 6.1 Control Room Environmen ............... 11 6.2 Temporary Circuit Alterations . . . . . . . . . . . . .

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6.3 Housekeeping / Material Conditions. . . . . . . . . . . . 13 6.4 Operational Oversight Functions . . . . . . . . . . . . 14 7.0 Exit Meeting . ....................... 16

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u I l . 2 l l L 1.0 Persons Contacted Within the scope of this inspection, interviews and discussions were conducted with Mr. John Franz and members of the licensee staff as necessary to support the inspection activities. A more comprehensive listing of those_ persons contacted is included as Attachment 1 to this report.

l L 2.0 Inspection Summary, Strengths and Weaknesses This was a special, announced operational readiness assessment team inspection of the Limerick I facilit This type of inspection is ' routinely performed at recently licensed plants in order to assess the operational readiness of a unit after completion of the plant's first refueling outag The inspection evaluated the physical condition of those plant sys-tems modified during the outage as well as the overall plant material condition. Methods of inspection included system walkdowns, review of l as-built drawings and general plant tours. The inspection also evalu-l ated the licensee's program for control of maintenance and testin To the maximum extent possible, surveillance testing and maintenance activities were witnessed by the inspectors. Selected procedures were reviewed for technical adequacy and compliance with the techni-cal specification Finally, an evaluation was made of control room licensed operator performance and the licensee's management control proces In general, the team found that there was adequate management control of operational and outage activities to support the resumption of power operation. One violation involving inadequate control of plant drawings was identified. One item involving surveillance testing of the Remote Shutdown Panel remains unresolved pending additional review. In addition, licensee strengths and weaknesses were discussed with the licensee at the exit meeting and are listed belo .1 Licensee Strengths The following significant strengths were noted:

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The operational verification form (OVF) method of specifying and documenting retests allows the details involving a specific retest to be consolidated on an informative, easy to use for The independent verification process was well controlled and used appropriately to ensure important tasks received inde-pendent review _ - - - - - - - - _ _ _ _ _ J

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Shift superintendent briefings used to disseminate information to on-shift personnel are thorough and effective. The shift briefings are routinely attended by plant management and the

  ' support departments so that the department supervisors are all aware of critical evolutions they need to support during the shif The surveillance test (ST) procedure format was goo Precau-tions, prerequisites and test acceptance criteria were clearly

' specified. Procedure steps and notes were generally concise

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and easily understandabl Shift superintendents are knowledgeable and have good control over shift' activitie Personnel performing surveillance tests were knowledgeable, safety conscious and thorough in briefing the operators on expected plant response to the test Plant personnel exhibit a professional and positive attitude in their dealings with each other and with outside agencies. This positive attitude was throughout the site and appeared to foster close cooperation among the various plant department .2 Licensee Weaknesses Several licensee weaknesses in programs and activities were noted:

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The liberal use of the Temporary Circuit Alteration (TCA) process has resulted in minor plant modifications being accom-plished and remaining in effect for extended periods of time without having received the same rigorous reviews and controls required of a permanent plant modification. Also, 10 CFR 50.59 safety evaluations in some instances appeared to lack the detail of analysis warranted prior to temporarily modifying a plant syste The procedures for the erection of temporary scaffolding in the plant does not fully address the potential affects on the operation of safety related equipmen Licensed operator training on various plant modifications appeared to warrant more specific details on the effect of the modification on plant system operation. There did not appear to be specific controls established which would ensure operators receive modification training in a timely manne Involvement by the Quality Assurance (QA) department and Independent Safety Evaluation Group (ISEG) in plant restart readiness determinations was not apparen _ _ _ _ _

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I 3.0 Inspection Purpose and Scope 3.1 Purpose l The purpose of this inspection was to assess the licensee's readiness to resume power operation following the completion of the first refueling outag I 3.2 Inspection Team l The inspection team consisted of an NRC' senior resident inspector as team leader, three resident inspectors, and a Region based inspecto .3 Scope

The inspection consisted of observation of licensee activities.and review of licensee program implementation in the following general areas:

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Plant Operations

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Maintenance Activities

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Surveillance Testing

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Operations Management Oversight

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Plant Modifications The inspection included some backshift coverage to allow observation of specific activities and backshift control of plant evolution .0 Plant Modifications Several plant modifications were inspected. The modification program is performed in accordance with the instructions contained in administrative procedure A-14, " Procedure For Control of Plant Modifications." The plant modification attributes which were reviewed by the inspectors include:

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Verification that plant modifications were accomplished in accordance with approved procedure Review of retest requirement Verification that affected plant operating procedures were updated to reflect performance of the plant modificatio Method and effectiveness of updating plant drawings prior to declaring the modification operationa Method and effectiveness of training operations staff on plant modifications and their effect on system and plant operatio Modification package review for identification of maintenance and ISI/IST program changes required due to the modificatio _ _ _ _ _ _ - _ _ _ _ _ _

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The' modifications selected for this inspection were those which were-specified license conditions which were required to be accomplished prior

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to plant startup following the first. refueling out' ag . 4.1 Summary of Plant Modifications Inspected: Modification 86-0034 This: modification was accomplished to satisfy condition 2.c(11) of-license'NPF-39 which required the installation of an additional-automatic isolation-valve in each.of the hydrogen recombiner lines penetrating the primary containment. This change added a second motor. operated valve on the outlet line of the post-LOCA hydrogen recombiners. The existing skid mounted isolation valve.is utilized as the second isolation valve on the inlet line Modification 86-0614 This modification replaces the existing Standby Gas Treatment System (SGTS) fans with higher capacity fans and also. connects the SGTS to

   'the refueling. area. This configuration provides the capability to
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provide the fan capacity to. allow simultaneous draw down of the . refueling enclosure and both Unit 1 and 2 reactor enclosures. . This ! modification was accomplished to satisfy license condition 2.c(14).

' Modification 86-0176 This modification was performed to provide a redundant residual ; heat removal (RHR) pump which could be operated from outside of the main l control room. The change. adds a transfer switch at the pump cir-

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cuit breaker cubicle and eliminates the necessity to: add temporary jumpers'to operate the "B" RHR pump locally. When the transfer switch ! is placed 'in the'" Emergency" position, the pump can be started and

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stopped using the test switch for the pump's circuit breaker. An indicating light was added to the main control room panel which will illuminate whenever the transfer switch is out of the'" Normal" position. This modification is required'by license condition 2.c.(12).

Modifications 86-0508 and 84-0026 f These modifications provide local pump starting capabilities for s the "B" emergency service water and the "B" RHR service water pumps respectively. The redundant remote shutdown operating feature is accomplished in the manner described above for the "B" RHR pump and also is required by license condition 2.c.(12).

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Modification 84-0106 The purpose of this modification was to provide aut'matic o and diverse

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    ' return line inside containment and outside containment isolation-valves and the drywell chilled water supply and return line outside containment isolation valves. This requirement is contained in-E     license condition 2.c.(10).

4.2 Inspection Results-The modification packages. examined appeared to be complete and p indicated that the A-14 procedure was being used to implement plant-

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modifications. Operational verification forms (0VF's) were included and detailed the testing to be performed. Various plant operating procedur_es were. reviewed and in all cases were found to have been revised to incorporate changes which were'a result of the plant modifications. Procedure A-14 Appendix 4, " Procedure / Specification Checklist," .was properly used to-identify procedures which required

',     changes and to notify the modification coordinator when the changes

, had been approved by the Plant Operations Review' Committee, PORC.

i Appendix'4 also specified maintenance procedures requiring update One apparent violation involving inadequate control of Category I (operations related) drawings was identified. 10 CFR 50, Appendix B, Criterion VI, requires controls to be established in the issuance of

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I documents,... such as drawings, including changes which prescribe all activities affecting qualit In one instance, an incorrect version of an as-built drawina was present in the main control room and the maintenance request coordinator's office. These drawings did not i reflect changes made to the plant per modification 86-0508. The affected drawings were E-15, " Single Line Meter and Relay Diagram - 4 KV Safeguard Power System - Unit 1." The other case of inadequate control of plant drawings also involved the E-15 drawing. In this  ; instance the modification coordinator's designee failed to-identify  ; '. drawing E-15 on A-14 Appendix 7, "As-Built Drawing Update Form," as a I Category I drawing requiring changes. This resulted in drawing E-15 not being updated during the implementation of modification 84-002 ' The inspector informed the licensee that the inadequate control of plant drawings constituted a violation (87-19-01). A similar violation was in identified in Inspection Report 50-352/87-0 One weakness identified in the plant modification process was that of licensed operator training on plant modifications. Per procedure A-14, Appendix 3, " Modification Training Bulletin," is to be utilized for any immediate training deemed appropriate by the operations engineer. Although the modification training bulletins are prepared and distributed to the operations and training departments they some-times lack the details necessary to be used effectively. For example

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modification 86-0176 training bulletin _ simply states that the modi-fication will allow the "B" RHR pump to be started locally but does-

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not discuss other aspects of system operation such-as whatlinterlocks orfauto-start features are bypassed or disabled when operating.in the " Emergency" mode. Also'there does not appear to be a mechanism iniplace to_. ensure that all operators have received the immediat training when'it is deemed' appropriate'. If an. operator misses th shift ' briefing when a' modification was discussed, -he may not.become aware of'the modification and its:effect on system operation until he receives his required reading package which is distributed on a monthly basis by the training departmen It wasLalso noted that several hours of formal training time was devoted to the review of major plant modifications accomplished during the outage. This type of training'can be an effective way to introduce operators to_ major modifications before they become-operational, however, an effective training method should also be

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available for those modifications 'which do not not permit long range planning and classroom trainin The labeling program for newly installed switches, circuit breakers, .

 . valves and other components appears to be done in a timely and    1 thorough manner such that operators can easily identify these new component .0' Maintenance and Surveillance The inspectors reviewed the plant maintenance and surveillance testing'    ,

programs. In the maintenance area the. inspection focused primarily on program aspects rather than specific activities since the plant was near-ing the startup and the. bulk of the activities involved retesting in lieu o actual performance of maintenanc In the area of surveillance testing the inspection included a review of program aspects, observation of in-progress testing,'and reviews of a completed tes .1 Maintenance The inspectors reviewed the licensee's program for identifying, tracking and implementing corrective maintenance. In particular, the status of outstanding maintenance request forms (MRFs) requiring closure prior to restart was evaluated. The licensee appears to have. implemented an adequate program for prioritizing and tracking outstanding corrective maintenance. The computerized history and maintenance programs (CHAMPS) system is a computer based maintenance request program which allows timely processing of MRFs while main-taining strong contro In addition, the CHAMPS system provides a means of obtaining an up-to-date status on open MRFs. The inspector reviewed the listing of all MRFs currently open in CHAMPS. Based on this review and discussions with personnel the licensee appears to maintain the maintenance backlog at a reasonable level, and has _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ - -

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i l identified the outstanding MRFs requiring closure prior to restar A sample'of MRFs were reviewed to evaluate the applicability of prescribed post work testing. The licensee's Operational Verifi-l cation Form (OVF) system appears to provide good cortrol of post maintenance testing. The OVFs reviewed wer;e clear and thoroug The inspector noted that several levels of licensen management i appeared actively involved in oversight of ' ongoing maintenanc During backshift tours the inspector observed on-shift maintenance division foreman touring active work areas to evaluate job status and housekeeping. Senior plant management attention to general plant conditions was also evident. On several occasions the superintendent of services was observed leading organized plant walkthroughs to review general housekeeping condition .2 Surveillance The inspectors evaluated the licensee's surveillance test program through conduct of personnel interviews, program administrative , procedure review, observation of testing in the field, and technical 1 review of test procedure adequacy. The licensee appears to have ' established a well organized surveillance test scheduling syste The computer based schedule is maintained by a cognizant engineer who issues weekly test requirement summaries to the ' implementing groups. Discussions with this cognizant engineer and personnel in the organizational areas responsible for test implementation indicates that good communication and feedback exist. Those sur-veillance tests required prior to mode change had been identified and implementing groups appeared to clearly understand their responsibilitie The format of surveillance test procedures reviewed was goo Precautions, prerequisites and acceptance criteria were clearly i specifie Each surveillance test included reference to the tech-nical specification requirement which it satisfie Procedure steps and notes were generally concise'and easily understandabl The licensee's program for independent verification of operating activities was particularly strong. After completion of testing, the procedures require that a technically qualified individual, not previously involved in test conduct, verify proper system restoratio This method provides for a true independent veri-fication and results in a high degree of confidence in the system configuratio Personnel performing the tests were knowledgeable and safety consciou Individuals reviewed the applicable test procedures prior to entering the control room. The control room operating

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shift was thoroughly briefed on expected alarms, equipment actu-ations and system operability impact before beginning test A copy of the procedure was maintained and used at each test . _ - _ _ _ _ - _ _

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,V ,gmiy % A - location. On several occasions procedural errors or discrep-ancies.were: identified. In each case, testing activities were

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,.r ' suspended'and the discrepancies resolved. After completion of m W^ . testing proper independent verifications were performed and the , +$

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   ' control room staff was briefed on the test result u   Remote Shutdown Panel Test-i i',    The inspectors witnessed portions of the Remote Shutdown System
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Operability Test, ST-1-088-320-1, during the startup preparations' u '

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from the cycle 1 refueling outage. Generally _the test was conducted well and adhered to the requirements of the surveillance test (ST).

Apparently portions of the remote shutdown panel instrumentation and controls are not included in the ST. The following concerns were developed:-

'<   The inspector. reviewed portions of surveillance test ST-1-088-320-1, g    Remote Shutdown Panel (RSP), for technical adequac The remote 1  o  shutdown system at: Limerick consists of a central control panel.

i containing monitoring.and control instrumentation,'and transfer l switches. The design function of the remote shutdownLtransfer " switches is to isolate potentially faulted control room circuits fro , the RSP and the field components. The transfer switches also enable the alternate RSP control circuits. The isolation function of the 3~ transfer switches is important in maintaining system operability during a postulated control room fir Technical Specification 4.3.7. * requires that remote shutdown control switches be demonstrated operable by verifying their, capability to perform their intended

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   . functio The inspector identified that the current test procedures-do.not'directly verify that the. normal main control room circuits are isolated upon operation of the remote shutdown transfer switche If the. isolation function of the switches is not tested the capability of the switches to perform ag designed may not be assured. The licensee expressed concern that the type of testing needed to verify the isolation function might require opening pin-Jacks and lifting
   ' lead The inspector agreed that excessive circuit alterations

,. should be avoide However, alternate methods of testing may exist l -which would better verify the isolation feature while minimizing l .

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required alterations and should be evaluated by the licensee. This ' item is unresolved pending additional review (87-19-02).

Technical Specification 3.3.7.4 requires that the remote shutdown system instrumentation and controls listed in Table 3.3.7.4-1 be

<-   operable. This table includes the RSP reactor core isolation cooling (RCIC) flow controller. Technical Specification 4.3.7.4.1 requires that each of the remote shutdown monitoring instrumentation channels be demonstrated operable by performance of a channel calibration at the frequency shown in Table 4.3.7.4-1. The RSP RCIC flow controller is not listed on Table 4.3.7.4-1. Review of surveillance procedures s

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     :* 4 and discussion'with the licensee indicates that the flow controlier is removed from. the panel and calibratml periodically. Thisinsths ment calibration,' however:may not satisfy the channel calibration-
 -. requirement and the RCIC turbine contnoller appears to be not fully tested. In addition,. the; inspector noted th'at the remote shutdown . ~

transfer switch which enables the 'use of the RSP RCIC flow controller - is not tested. iThis testing may 'have been. overlooked due to the'

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 : omission-of the' flow controller from Technical Specification. Table   )
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Another concern developed as'a. result of. obtaining an 150 chm read-ing when an inf.inite reading was required by the ST. The,1.icensee-explained that this occurred wi.th AC operated valves a.nd resulted from two other current loops present11n the circuit, but'that'the procedure demonstrated-that the ememency transfer swit6h had effectively performed its functirw.; The inspector asked if the

 : licensee had formally evaluated the electrical resistance of these-loops either by engineering calculations or by actual measurement The licensee: stated that this had not been accomplished but would incorporate this into additional action requirements of the ST The'

inspector. reviewed the previous remote shutdown panel ST's to determine if this-had been formally evaluated; it had not. Further review 'of'the ST's indicated that the readings -in question read

 " infinite" during the previous test. The licensee should determine why the discrepant condition exist between tests. This item is-unresolved pending further revie (87-19-02)
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Licensee management concurred' with the inspector's concerns and agreed to evaluate methods for testing the remote shut.down transfer switch isolation functions, to_ add.the required RCIC flow controller testing, and.to revise Technical Specif t:ation Taole 4.3.7.4-1 to include surveillance requirements for the RCIC. flow controlle After the completion of.the-inspection, followuq by the. Senior ] l ResidentInspectorhasdeterminedthatthe'lfy(nseehastakenactions to resolve the inspector's concerns relative.to the performance of  ! the test. The details will be provided in inspection report 50-352/87-2 List of witnessed surveillance tests:

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      . ST-2-074-415-1  APRM Calib'r'ation and Functional Test of Chann/1 D  ,'

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RT-1-055-331-1 HPCI Overspeed Trip Test j

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ST-2-059-600-1 ADS Accumulator Backup Compressed , , Gas low Pressure Functional Test ,,

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ST-1-088-320-1 Remote Shutdowr System Operability , l Test .

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y - ST-2-088-403-1 Remote Shutdown Monitoring - RCIC yr W '

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System Flow Calibration l@ - ST-2-088-404-1 Remote Shutdown Monitoring - RCIC g Turbine Speed Calibration

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ST-1-088-320-1 Remote Shutdown System Operability f Test 6.0 Conduct of Operations

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On a' daily basis, the inspectors witnessed control room operations to

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assess the performance of licensed and non-licensed operators, access controls, use of procedures, adherence to technical specifications, and general control room environment. These observations were made during normal and backshift hours such that all shifts were observed on a random l basis._ In addition to reviewing the plant status by control room annun-

.3  ciators; recorders, and switch positions, the following records and
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Technical Specification Interpretation Log

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Operator,ChiefOperator)

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Various Integrated Operating Procedures 6.1 Control Room Environment and Logs

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Throughout the inspection period the control room was maintained in a highly professional manner. Licensed and non-licensed operators were

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found to be fully aware of plant status and knowledgeable of their duties and responsibilities. Access to the control room was ade-quately controlled and no potentially distracting activities were witnessed by the inspectors. Especially noteworthy was the perform-ance of the shift superintendents, who are the senior licensed shift individuals on site. They maintained close control of all plant activities and ensured control room behavior remained professional __ -_

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    :and' businesslike. The shift turnover meetings were found to_be'
,    thorough:and.very. valuable' as a means of- keeping everyone's attention' .
    < focused on'high priority work.- The control room logs were found to '

be genersily; satisfactory, although their.usefuln'ess would be

,     improved if entries concerning some plant evolutions.were more detaile n
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   . Temporary Circuit Alteratio'ns During the review of temporary circuit alterations (TCA) log, the inspectors noted a large number of TCAs (approximately 200) and.a w

• number of TCAs that have been outstanding for a considerable length of time. The inspector' reviewed the TCA log with a shift technical advisor (STA),1who according to procedure had just completed a quarterly review of outstanding TCAs. The quarterly STA review as required by procedure A-42, " Procedure For Control of Temporary Circuit Alteration," evaluates the TCAs continued applicability and documents proposed action or disposition of TCAs installed for '

greater than 3 month The review does not perform safety evalua- ; l

&    tions on.long outstanding TCAs, in some cases almost three years, to {

c reassess the validity of the original safety evaluatio Considering the number of outstanding TCAs this may have the potential to affect plant safet Procedure A-42 requires that prior to implementing a TCA considera-tion.be given for procedure changes as delineated in FSAR section 13.5.1.5. The TCA checkoff list does not incorporate any considera-tion for procedure changes. In some cases surveillance test (ST) requirements have been considered and the appropriate changes mad In another case, TCA 846, the ST procedure was changed, but the annunciator alarm response procedure for the rod block monitor was not changed to reflect the addition of a clamp at 106%. This TCA was implemented in February 1987. In addition to procedure changes, lack of appropriate drawing changes may be significant. TCA 246, imple-mented in March 1985, effectively changed the logic for the chlorine detector isolation of control room HVAC. The logic was changed from a 1/2-to 1/1 logic to close a HVAC isolation valve upon chlorine gas detection. This has not been reflected in controlled plant drawings for the control room HVA In most cases the implemented TCA~1s awaiting completion of a formal plant modification that will initiate procedure and drawing changes, as well as subject the already imple-mented modification to a complete design review. Procedure A-14,

    " Procedure For Control of Plant Modification," specifies the formal design review process necessary for a modification. In effect the TCA process is bypassing required reviews as delineated in procedure A-14. These are eventually conducted, but long after the TCA has implemented the modification in the plant.

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The chlorine detector logic, which was modified by TCA 246 as dis- ' cussed above, is a change to the FSAR. FSAR Section 9.4.1.1 and control enclosure HVAC PSID M-78 sheets 1 and 2 describe the function ' and logic for chlorine detectors. The licensee was questioned to determine if this change to the FSAR effected in March 1985 had been submitted to the NRC in the annual 10 CFR 50.59 report. This item is unresolved pending review of the 10 CFR 50.59 report (87-19-03) At the exit interview the licensee committed to review all TCA's prior to startu This. review will include.an assessment of the original safety evaluation's continued validity for each TCA. In addition, the licensee should consider better defining TCA use and duration in procedure A-42 that would prevent its use as a modifi-cation procedure. Further the licensee stated that a review would be conducted to evaluate a method to implement minor plant modifications ir, a timely manner. Inspector followup will be conducted in this area to insure minor plant modifications are properly implemente The inspector also reviewed TCA No. 170, dated December 12, 198 The original design of the Nuclear Steam Supply Shutoff System (NSSSS) included automatic closure of the main steam isolation valves (MSIV) and the main steam line (MSL) drain valves on a level 2 isola-tion signa In addition, the MSL bypass leakage barrier vent valves HV-41-140 and HV-41-141, were designed to open on the level 2 signa During construction the MSIV and MSL drain valve isolation signals were changed from level 2 to level 1. The MSL bypass leakage barrier vent valve isolation signal, however remained at level 2. This inconsistency was identified in 1984. At that time jumpers were installed to prevent a level 2 NSSSS signal from automatically open-ing the MSL bypass leakage barrier vent valves. This change was processed to preclude the possibility that the vent valves could open at level 2 while the MSL drain valves remained open, venting nuclear steam into the are The main steam lines and MSL drain lines terminate outside secondary containment and thus provide a possible unfiltered leakage path following an accident. A MSL bypass leakage control system was installed to prevent this unfiltered leakage. The MSL bypass leakage barrier vent valves serve to limit the leakage through the MSL drain lines by venting possible leakage back to the secondary containmen TCA No.170 altered the NSSSS isolation logic and modified -this portion of the venting system. The safety evaluation attached to the TCA was not clear in addressing the loss of the vent valve leakage control function. The TCA Technical Review Check Off List attached to TCA No. 170 appeared to have been improperly completed in that it is not clear that the impact of the loss of the leakage control function was considere This temporary alteration has remained in place for almost three years without being subject to the extensive design review process normally applied to station modification This item is unresolved pending reveiw of the licensee response to weaknesses identified in section 2.2. (87-19-03) _

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6.3' Plant Housekeeping and Material Condition I i The inspectors toured the facility on a daily basis to assess the j level of housekeeping and the material status of plant equipmen Although there was'a limited amount of outage related work still in progress during this inspection period, the cleanliness of the plant' was found to be good. System walkdown inspections were conducted on the emergency service water and core spray systems. No deficiencies were identified that had an adverse effect on safety related system operability or were not previously identified by the licensee. The limited number of contaminated areas indicates that the licensee has given contamination. control an adequate level of attentio During plant walkdowns throughout the inspection period, the inspec-tors noted a significant number of erected scaffolds in the vicinity of safety related equipmen The station's scaffolding control program is detailed in Administrative Procedure A-30.1 " Control of In-Plant Scaffolds and Work Structures." This procedure assigns responsibilities to specific individuals for authorizing, inspecting and controlling the use of scaffold It also requires the scaffold coordinator to ensure that the erected structure does not impede 'i access to fire stairway enclosures, fire exits, or fire doors or significantly impact the function of installed fire protection equip-ment or features. The procedure, however does not address the impact of the scaffold on safety related equipment and does not address a review of seismic considerations. The operability of safety related

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seismic category one equipment could be affected by scaffolding. The ; licensee stated that scaffolding was being disassembled as work progress permitted and the outage neared completion, however the inspector identified scaffolding in the emergency service water pipe chase that was 16 months old indicating that a more aggressive approach for controlling scaffolding is needed. The licensee's program for the control of scaffolding was identified as a weaknes .4 Plant Oversight Functions The inspectors attended two sessions of the Plant Operations Review Committee (PORC) on August 18, and August 20 to determine if PORC is adequately addressing matters related to nuclear safety. The purpose of these meetings was to assess the plant's readiness for startup and I subsequent power operation. To make this assessment, PORC utilized l an OPCON Change Review checklist which contained the following review l items:

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LCO Log

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Review of outstanding TCA's  !

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Review of CHAMPS reports focusing on safety system status: U-_ __ _ _ __ _ _ _ _ ^

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l l Maintenance Instrument and Controls l Outage Planning

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Review of progress of GP-2

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Review of outstanding blocking permits

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Review of the Corrective and Preventive Maintenance

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Equipment Status Logs

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Review of GP-18 (Startup only)

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Alarm status

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Plant Modification status

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Surveillance status (Out of Surveillance Report and ST Coordinator Open Items Log)

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Regulatory commitments

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Core Component Transfer Authorizations (CCTA) ready for issue

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PORC Commitments

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Items unique to the current startup j A clear focus on safety related issues was maintained during all of the PORC discussions witnessed by the inspector. The August 20 meeting was also attended by two members of Nuclear Review Boar The QA activities relating to the preparation for plant startup and the planned witnessing of plant activities was reviewed. In prep-aration for this startup, the QA organization planned to perform a , check on selected system checkoff lists including RHR, core spray, j emergency service water, diesel generators and the automatic depres- ) surization system. The status of surveillance tests and modification j packages is also reviewed by QA. Prior to plant startup, QA/QC is i required by QADP-34 " Review of PECO QA/QC Open Quality Items That May i Affect Reactor Startup" to provide a list of startup concerns to the l station manager. However, no reply to these concerns is required nor I does QA/QC have to be satisfied with the actions to resolve the ' identified concerns. In addition, PORC is not provided the startup concern list nor are they specifically required to address the QA/QC issue l l l

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' . The Independent Safety Engineering Group (ISEG) does not conduct an independent assessment of plant readiness for startup nor are they , required to' certify that they do not know of any outstanding safety

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issues that need resolution prior to startup. The lack of a formal . and coordinated involvement by site QA and ISEG in determining the ~l plant's readiness for startup was noted as a programmatic weaknes t The station manager stated at the exit meeting that he recognized this weakness and actions'would be taken to strengthen the inter-action between the plant staff, QA and ISE Throughout the inspection period the inspectors attended the plant management / supervision status and planning meeting These meetings consist of an 8:00 a.m. status meeting conducted by the shift super-intendent, a 10:00 a.m. outage planning meeting, and an 11:00 TRIP 0D meeting to schedule activities for the next three days. Each of these meetings appear to be valuable to plant supervision in assessing plant conditions, establishing priorities, and ensuring that all groups are working toward the same goa .0 Exit Interview The inspectors met with Mr. John Franz and other licensee personnel periodically and at the end of the inspection to summarize the scope and findings of their inspection activitie Based on Region I review and discussions with the licensee, it was determined that this report does not contain information subject to 10 CFR 2 restriction _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ^

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Attachment 1 Entrance And/0r Exit Interview Attendees Philadelphia Electric Company ,

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R. Alejnikov, Modification Coordinator ' J. Burke,. Nuclear Operations Quality Assurance Auditor J. Corcoran, Manager of Quality Assurance, Limerick 2 R. Dubiel, Senior Health Physicist G. Edwards, Technical Engineer C. Endriss, Administrative Engineer D. Fetters, Engineering and Research, Project Manager J. Franz, Manager - Limerick Generating Station R. George, Electrical Engineer E. Gibson, Quality Assurance Engineer R. Hennessey, Quality Control Supervisor, Operations QC L. Hopkins, Operations Engineer J. Isaacs, Test Engineer D Klein, Bechtel Engineering

~J. Law, Outage Planning Engineer G. Leitch, Manager - Nuclear Generating Department M. McGill, Enginner C. Mengers, Senior Engineer - Limerick Licensing J. Milito , Supervisor - Limerick Field Engineers J. Rupert, Supervisor - Site Quality Assurance R. Scott, Superintendent - PECO Construction J. Spencer, Superintendent of Plant Services W. Texter, Supervisor - Limerick Maintenance C. Wiedersum, Licensing Engineer  !

G. Zaimus, Project Engineer i NRC R. Borchardt, Senior Resident Inspector S. Kucharski, Resident Inspector J. Linville, Section Chief J. Lyash, Resident Inspector L. Scholl, Reactor Engineer , J. Wechselberger, Resident Inspector J i I l

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