IR 05000352/1990002
| ML20033F791 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/20/1990 |
| From: | Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20033F788 | List: |
| References | |
| 50-352-90-02, 50-352-90-2, 50-353-90-02, 50-353-90-2, NUDOCS 9004030077 | |
| Download: ML20033F791 (21) | |
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i U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
Report No.
90-02 90-02
Docket No.
50-352 50-353
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l License No.
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NPF-85 Licensee:
Philadelphia Electric Company Correspondence Control Desk P.O. Box 195 bayne, Pa 19087-0195
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Facility Name:
Limerick Generating Station, Units 1 and 2 Inspection Period: January.1 - January 29, 1990
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Inspectors:
T. J. Kenny, Senior Resident Inspector
L. L. Scholl, Resident Inspector
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M. G. Evans, Resident Inspector
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A. L. Della Greca, Reactor Engineer 3bo!9 0
/m oA tw Approved by:
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Lawrence T. Doerflein, Chis f, Date
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Reactor Projects Section 2E
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Summary: Routine daytime (207 hours0.0024 days <br />0.0575 hours <br />3.422619e-4 weeks <br />7.87635e-5 months <br />) and backshif t/ holiday (20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />)
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inspections by the resident inspectors consisting of (a) plant tours, (b)
observations of maintenance and surveillance testing, (c) review of LERs and periodic reports, (d) review of operational events, (e) system walkdowns, and (f) results review of power ascension activities on Unit 2.
During this inspection period:
The Unit 2100 hour0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> warranty run was performed marking the
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completion of the power ascension test program.
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Safety system walkdowns were performed on the control enclosure
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chilled water and control room emergency fresh air system.
A violation of 10CFR 50.49 paragraph (f) was idantified during an
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inspection of cabling to the Unit 2 post-LOCA radiation monitor.
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i DETAILS 1.0 Persons Contacted Within this report period, interviews and discussions were conducted with members of PECo management and staff as necessary to support inspection activity.
2.0 Operational Safety Verification The inspectors conducted routine entries into the protected areas of the plant, including the control room, reactor enclosure, fuel floor, and drywell (when access is possible).
During the inspection, discussions were held with operators, health physics (HP) and Instrument and Control (!&C) technicians, mechanics, security personnel, supervisors and plant management. The inspections were conducted in accordance with NRC Inspection Procedure 71707 and affirmed PECo's commitments and compliance with 10 CFR, Technical Specifications, License Conditions and Administrative Procedures.
2.1 Inspector Comments and Findings
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At the start of the inspection period Unit I was operating at 100%
power and Unit 2 was at approximately 87% and increasing power to establish the plant conditions for the performance of the warranty run.
On January 2, Unit 2 commenced the 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> warranty run.
On January 5, Unit 2 drywell atmosphere was inerted with nitrogen for the first time. No problems were encountered.
On January 8 at 12:01 a.m., Unit 2 completed the startup test program and commenced commercial operation.
On January 8, a reactor enclosure low differential pressure isolation was received when Unit 2 reactor enclosure ventilation was restored following maintenance and troubleshooting. The isolation occurred when the main control room " Auto / Reset" switches were placed in auto. The operators then found that the local " Auto / Test" switches had been inadvertently left in the test position following the main-tenance and troubleshooting.
Both trains of Standby Gas Treatment System (SBGTS) and the 2A reactor enclosure recirculation system started and operated as designed.
The NRC was notified via the Emergency Notification System (ENS). The cause of this event was i
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personnel error in that the " Auto / Test" switches were not returned to normal prior to resetting the isolation.
The licensee counseled the personnel involved on the importance of proper communication and the need for transferring accurate and complete information. The licensee's root cause analysis and additional corrective actions are subject to future review as part of the resident inspector's routine Licensee Event Report (LER) review.
On January 12, PEco briefed the resident inspectors on a problem which occurred during a radioactive waste shipment. The NRC Regional Administrator was not notified of a highway controlled route shipment, prior to the shipment, as required by 10 CFR 71.97(c)(1). As a result of this occurrence PEco has revised procedure RW-222, " Shipment of Radioactive Waste to Barnwell," to include signoffs to document the performance of the required notifications.
The inspectors have reviewed this event and determined that it satisfies the criteria for a licensee identified violation as stated in 10 CFR 2 Appendix C, Section V.G.1 and as such a notice of violation will not be issued (NCV 50-352/90-02-01).
On January 12, two isolations of the reactor water cleanup (RWCU)
system occurred on Unit 2.
The first isolation occurred due to a high differential flow condition while placing the 2A filter de-mineralizer in service. The high differential flow condition was apparently due to the filter demineralizer not being completely full of water thereby resulting in the inlet flow being higher than the outlet flow. The second isolation was also the result of a high differential flow signal.
In this case, the flow mismatch problems were due to relief valve leakage. The relief valve was subsequently repaired and the systo, returned to operation.
Reactor coolant chemistry was not adversely affected and remained within the technical specification limits during the isolations.
On January 19, the resident inspectors from Limerick and Peach Bottom and the NRC Division of Reactor Projects Section Chief
attended a briefing by the Nuclear Engineering Division (NED)
organization.
The meeting was held at the Nuclear Group Headquarters in Chesterbrook, Pennsylvania and served to update the NRC personnel on the current engineering group organizational alignment, staffing and significant present and planned work efforts.
On January 24, while restoring the Unit 1 ' A' circulating water loop to service, approximately 40,000 gallons of water were spilled due to an unsecured waterbox manway.
See section 5.0 for additional details.
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On January 26, the NRC was notified via the ENS that a design i
deficiency was found in the main control room ventilation system.
The system has two isolation modes, high radiation and high chlorine.
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For a high radiation isolation the outside air is automatically diverted through the emergency fresh air filter system and recir-culated while during a chlorine isolation the air intake valves shut and the control room air is filtered and recirculated. The design deficiency is that a single component failure could prevent the auto-matic changeover from the radiation to chlorine isolation mode or vice versa. However, if either a radiation or chlorine isolation signal is received while the system is in its normal lineup, the proper isolation lineup will occur even in the event a single com-ponent failure occurs. The licensee has determined that no immediate actions are necessary since an analysis of the main control room
ventilation system in the radiation mode shows that sufficient time (at least two minutes) exists to take appropriate corrective actions i
from an outside chlorine release. Also, this analysis shows that there is sufficient protection from radiation in the chlorine isolation mode such that appropriate protective actions can be taken. The inspector reviewed the analysis and found it acceptable.
The licensee corrective actions to resolve this item are subject to further review
during the resident inspector's routine LER review.
At the end of the inspection period both Units 1 and 2 were
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operating at 100% power.
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2.2 Engineered Safety Feature (ESF) System Walkdown: (71710)
The inspectors verified the operability of the control enclosure chilled water and control room emergency fresh air systems by performing a walkdown of the system to confirm that system lineup procedures agree with plant drawings and the as-built configuration.
This ESF system walkdown was also conducted to identify equipment
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conditions that might degrade' performance, to determine that instrumentation is calibrated and functioning, and to l
verify that valves are properly positioned and locked as appropriate.
The following procedures, drawings and tests were reviewed:
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Drawing M-78 Control Enclosure HVAC Piping and Instrumentation Drawing OS78.1.A (COL)
Equipment Alignment for Normal Operation of Control Room HVAC System
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0$78.1.B(COL)
Equipment Alignment for Control Room HVAC Isolation and Emergency Fresh Air Supply FSAR Section 6.4 Habitability Systems Drawing M-90 Control Enclosure Chilled Water Piping and Instrumentation Drawing
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OS90.1.A(COL)
Equipment Alignment for Startup of the Control Enclosure Chilled Water System OS90.4.A(COL)
Equipment Alignment for Transfer of
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Refrigerant from/to Control Enclosure Chiller FSAR Section Control Structure Chilled Water System 9.2.10.2 Prior to beginning the walkdown of the Control Enclosure Chilled Water System and the Control Enclosure HVAC, the
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inspector reviewed applicable Piping and Instrumentation Drawings (P& ids) in the control room to ensure use of the most current drawing revisions for the walkdown.
The inspector noted that a P&ID stick on the Unit 2 side of the control room appeared to contain superseded controlled copias of sheets 1, 3 and 4 of P&ID M-78, " Control Enclosure HVAC (common)." The inspector notified PECo management of the apparently out of date drawings.
Upon investigation, the licensee found on the Unit 2 side of the control room, approximately seven common drawings which were not current revisions.
These drawings were promptly removed.
Investigation showed.that this occurred due to the combination of the following:
the subject drawings were inadvertently left in the Unit 2 drawing file when they should have been removed following system turnover during the Unit 2 startup program; and following system turnover on Unit 2, common drawings were purposely not updated and maintained with Unit 2 prints.
(Instead all common drawin s have been maintained and hung with Unit I documents.
- After review of the situation and verification that controlled drawings at other plant locations were current, PECo determined that no analogous situation exists or could develop which would result in a similar occurrence.
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d During the system walkdowns, the inspectors identified several discrepancies including a control enclosure chiller valve which was not included on any check off list, an unattached cover plate for a seismic IIA water tight enclosure, and several valves which were
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inadequately labeled. Also, two manual valves in the air purge line to the control room emergency fresh air system filter units were not labeled or controlled in the system check off lists.
The inspectors discussed these discrepancies with the appropriate system test engineers
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who stated that revisions to the check off lists and i
additional labeling would be completed as needed.
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inspectors did not identify any conditions which would
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impact system operability.
The inspectors had no further l
questions.
3.0 Update /Closecut of Open Items (92701, 92702)
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3.1 (Closed) Unresolved Item 50-352/88-20-03 Safeguard Battery Room Configuration This item documented a concern that spark producing equipment is located in the safeguard battery rooms and this condition combined with the sustained loss of battery room ventilation could result in a hydrogen explosion hazard. As stated in the Limerick Generating Station Safety Evaluation Report (NUREG-0991 Supplement 7)... "
Although the plant configuration is not in conformance with the t
Institute of Electrical and Electronics Engineers (IEEE) Standard
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484-1975, the staff concludes the arrangement is acceptable provided administrative procedures ensure that there is adequate ventilation to limit hydrogen accumulation, that there are periodic functional tests of the ventilation. system, and that appropriate actions are taken in the event that the ventilation system becomes inoperable."
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The inspectors reviewed the following administrative controls which have been implemented to ensure a reliable battery room ventilation system:
Auxiliary Plant Operator Day Shift Log 2 Rounds Sheet. These
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checks ensure that a battery room exhaust fan is running and that the normal and recirculation mode control dampers are in the correct position. These conditions are verified once per day.
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RT-1-078-420-0, " Battery Room HVAC Interlock Test." This
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test verified that with both battery room exhaust fans shut down, the system dampers realign to the recirculation lineup. Also, the exhaust fan trouble annunciator L
operation is verified.
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ST-6-078-320-0, " Control Enclosure HVAC Operability Test."
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i This test checks operation of the Emergency Switchgear/ Battery Room Supply Fans on a three month interval.
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L 578.9.B, " Routine Inspection of Auxiliary Equipment, SGTS,
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Emergency Switchgear and Battery Room Vent Systems." This procedure is used to perform periodic checks of the system to ensure normal fan operation and differential pressures across i
the filters.
Alarm Response Card, ARC-MCR-002 12. " Control Structure HVAC
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Panel OCC101 Trouble Alarm." This annunciator is actuated for
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the following battery room ventilation problems:
Exhaust Fan High Discharge Temperature
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Supply Fan Discharge Air High Temperature
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Supply Fan Discharge Air low Temperature
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Supply Fan Intake Air High Temperature
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Exhaust Fan A or B Trouble
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Supply Fan A or B Trouble
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Supply Filter High Differential Pressure
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Supply Filter Media Run Out
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The Alarm Response procedure has been revised to add direction
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to the operators to establish the recirculation mode of operation in the event both exhaust fans are lost and to ensure batteries are not charging until normal ventilation is established.
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Alarm Response Card, ARC-MCR-002 DS, " Control Enclosure Steam
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Flooding Damper Panel 00C729 Trouble." This card refers the operator to procedure S78.0.A, " Normal Operation of Control Enclosure HVAC Steam Flooding Dampers," in the event a damper isolates a room and could lead to a gradual buildup of hydrogen.
This procedure has been revised to add a precaution on the potential for hydrogen buildup and ensures the battery chargers
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are not in the equalize mode with a damper closed.
The Ventilation System instrumentation receives periodic
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calibration on a seven year interval and is tracked in the computerized history and maintenance planning system (CHAMPS).
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The battery charger outputs are also monitored and have an
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annunciator in the main control room. The annunciator alarms on i
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a low DC voltage, low AC voltage, high DC voltage and a no charge j
condition, Thus a condition which could lead to an excessive i
charging rate, and thereby an associated high hydrogen production
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l rate, would be promptly detected and investigated by operations i
personnel.
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Based on the above the inspector found the licensee's controls adequate and this item is closed.
4.0 Surveillance /Special Test Observations (61726)
During this inspection period, the inspector reviewed in-progress surveillance testing as well as completed surveillance packages. The inspector verified that surveillances were performed in accordance with
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j licensee approved procedures, plant technical specifications, and NRC Regulatory Requirements. The inspector also verified that instruments
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used were within calibration tolerances and that qualified technicians
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performed the surveillances.
Portions of the following surveillance
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tests were reviewed:
ST-6-092-311-2 D21 Diesel Generator Operability Test Run ST-6-092-312-1 D12 Diesel Generator Operability Test Run
ST-3-107-790-1 Control Rod Scram Timing ST-6-095-901-1 DIV I, 125/250 VDC Safeguard Battery Weekly Inspection ST-2-074-416-1 Average Power Range Monitor (ApRM) E Calibration / Functional Test q
During witnessing of ST-6-095-901-1 on January 24, 1990, the inspector noted that during the Return-to-Normal portion of the test the nonlicensed
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operator wiped, with a neutralizing solution, only the pilot cells which were used to get samples.
Step 7.3 of the procedure specifically states to wipe all battery cells with the neutralizing solution. The inspector questioned the operator regarding this step. The operator stated that his interpretation of the step concluded that only cells which could have been affected by the test performance needed to be wiped.
The inspector discussed this issue with PECo management.
Specifically,
the inspector questioned whether the step was correct as written, in
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which case the operator should have wiped each cell, or if the step was incorrect, therefore requiring a temporary procedure change.
PECo
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management determined that it was not necessary to wipe all cells, only those affected by the test performance and all others with evidence of
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electrolyte spillage.
ST-6-095-901-1 and 15 additional battery surveil-lance tests were revised.
In addition, operation's management issued a memorandum on January 26, 1990 to each Shif t Superintendent stressing the need for procedural compliance and that procedural execution should not rely on an interpretation of the intent by the performer. The inspector found the licensee's actions to be adequate and had no further questions.
On January 24, 1990, during the performance of ST-2-074-416-1, the inst-rumentation and control (I&C) technician posted at panel 200606 in the auxiliary equipment room inadvertently placed the mode switch on RISH-41-1K603C, "C Main Steam Line Radiation Monitor" to standby.
Step 6.5.3 of the ST required placing the Intermediate Range Monitor (IRM) G mode switch to standby.
The incorrect action caused an inadvertent half scram on reactor scram channel A2. After determining the cause of the half scrats, the RISH-41-1K603C mode switch was returned to operate and scram channel A2 was reset. A subsequent PECo investigation, using the Human Performance Evaluation System, revealed that the cause of this
"near miss" was confusing and/or inadequate labelling.
PEco I&C personnel took prompt corrective action on January 26, 1990 to prevent recurrence.
Human factor enhancements were made to panel 10C606 by the addition of color coded lines for instrument drawer separation and clarification of channel tagging. The inspectors toured the auxiliary equipment room and noted the marked improvement in equipment labeling. The inspector had no further questions.
5.0 Maintenance Observations (62703)
The inspector reviewed the following safety related maintenance activities to verify that repairs were made in accordance with approved procedures, and in compliance with NRC regulations and recognized codes and standards. The inspector also verified that the replacement parts and quality control utilized on the repairs were in compliance with the licensee's QA program.
9000194 Leak Test and Repair of Unit 1 Main Condenser 9000371 Control Enclosure Chiller-B Refrigerant Charge Distillation During restoration of the Unit I circulating water system, approximately 40,000 gallons of water were discharged to the turbine building floor and subsequently collected in the radwaste system. The cause of the spill was that the manway on the intermediate pressure condenser was not bolted in place following the maintenance activit *
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The problem was discovered while refilling the waterbox when the main condenser area room flooding alarm annunciated. Upon receipt of the alarm, the main control room operator immediately shut the water box inlet valve to terminate the spill. The manway was then secured and the waterbox returned to service. PECo subsequently performed a root cause analysis (RCA) which identified the following causes of the event:
No single group was directing the work (both chemistry and
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maintenance were involved in the leak testing);
No maintenance procedure was used to control the activity;
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ALARA concerns caused personnel to rush during the restoration
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of the waterbox; and Communication problems and the extended duration of the job
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resulted in a loss of status of the manways over time.
The RCA also identified the following recommended corrective actions to prevent recurrence:
Revise the maintenance procedure such that it applies to and is
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used for all aspects of condenser work. Also add specific manway closure signoffs to verify proper system restoration; Centralize control of this work within one group;
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Include manway closure verification on the blocking permit; and
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Investigate generic implications of internal flooding and
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adequacy of plant controls.
The inspectors found the licensee's analysis and proposed corrective actions adequate.
Implementation of the corrective actions is subject to future review as part of the routine resident inspection program.
6.0 Power Ascension Test Program (PATP) Unit 2(72301,72400,72532)
6.1 Overall Power Ascension Test Program At the beginning of this report period reactor power was being increased in preparation for the warranty run (100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> at 100%
power) which began on January 2, 1990 and was successfully completed on January 6, 1990.
Final management approval of the warranty run test results and 2STP-99.6, " Test Plateau D-100% Rod Line Testing" occurred on January 7,1990.
Unit 2 was declared to be in commercial operation as of 12:01 a.m. January 8, 199 <
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6.2 Power Ascension Test Results Evaluation All startup tests for the warranty run were reviewed to verify that all acceptance criteria had been satisfied, the Test Exception Reports (TERs) were adequately resolved, and that the test results were appropriately reviewed and approved.
In addition, the inspector reviewed all TERs which were open at the end of previous test conditions to ensure appropriate resolution, retesting and approval had occurred.
No discrepancies were noted.
The inspector reviewed the results of 2STP 99.6, " Test Plateau D-100% Rod Line Testing," approved January 7,1990. This procedure was reviewed to ensure that all planned testing at the 100% rod line had been completed and that TERs remaining open could safely be carried forward into commercial operation.
Five TERs remained open at the end of the warranty run.
The TERs documented the following issues:
(1) continued observation of jet pump 17/18 performance including evaluation of nozzle plugging criteria; (2) additional troubleshooting and testing of the offgas system; (3) testing of the newly installed vibration probe for the High Pressure Coolant Injection (HPCI) system turbine during future HPCI operation; (4)
calibration, repair and retesting of flow indicators and sample coolers on a chemistry sample station; and (5) conduct of a planned Turbine Trip Test (as discussed in Inspection Report 50-352/89-23)
and 50-353/89-31, section 6.3).
The inspector reviewed the TERs and found it appropriate for the TERs to remain open beyond formal completion of Power Ascension Test Program.
The inspector verified that five PECo Nuclear Group-Nonconformance Reports (NCRs) were written to transfer responsibility for the above issues to PEco plant staff and to assure closure of the issues.
Based upon the above review, the inspector concluded that PEco had satisfactorily completed the Limerick Unit 2 Power Ascension Test Program.
This inspection represents the final NRC Region I review of the power Ascension Test Program and completes the NRC 2514 inspection program.
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7.0 Review of periodic and Special Reports (90713)
i Upon receipt, the inspector reviewed periodic and special reports.
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review included the following: inclusion of information required by the NRC; test results and/or supporting information consistent with design predictions and performance specifications; planned corrective action for l
resolution of problems; and reportability and validity of report I
information.
The following periodic reports were reviewed:
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Monthly Operating Report - December 1989 1989 Annual Report of all Challenges to Safety Relief Valves The inspector had no questions regarding these reports.
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8.0 Licensee Event Report Followup (90712)
The inspector reviewed the following-LERs to verify that reportability requirements were fulfilled, that immediate corrective action was taken,
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and that corrective action to prevent recurrence was accomplished.
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accordance with the above inspection module the inspector considers the following reports closed. The inspector had no further comments or
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questions except as noted.
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LER Number Subject / Comments
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1-89-059 During the performance of surveillance test ST-2-026-018-8,
"NSSSS-Reactor Enclosure Ventilation Exhaust Duct Radiation-High Division IA Functional Test," an instrumentation tech-nician inadvertently touched a test jack jumper with a key chain and caused a short circuit to ground.
The short caused a fuse to blow which resulted in several system isolation signals.
The fuse was replaced and the isolations reset within approximately 30 minutes.
There was no sig-nificant effect on plant operation due to the occurrence.
A root cause analysis investigation was performed and resulted in several corrective actions to prevent recurrence.
The task force which was assembled to perform the root cause analysis on this event also reviewed all previous LERs which documented similar occurrences. As a result of this review,
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an Instrumentation and Controls Good Practice Guideline was developed and focuses specifically on surveillance testing in the auxiliary equipment room. This guideline is being
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presented in the technician continuing training sessions.
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The inspector found this to be an excellent example of the use of root cause analysis techniques.
1-89-060 This LER reported leakage of charcoal from the Standby Gas Treatment System (SBGTS) charcoal adsorber beds due to failed welds on the retention screens.
The design of these filters is unique to the SBGTS at Limerick.
This event was previously reviewed in section 5.0 of NRC combined inspection report 50-352/89-23 and 50-353/89-31.
PECo has subsequently written procedures RT-1-076-901-0 and RT-1-076-902-0 to perform monthly inspections on the A and B SBGTS charcoal
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adsorber beds and retention screens. The results of an engineering review to determine the root cause for the weld failures will be provided in a supplement to this LER.
The inspector had no further questions, at this time, concerning this event.
2-89-015 During startup from an outage and during low power operation, a problem with the '2B' Reactor Protection
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System (RPS)/Uninterruptable Power Supply static inverter resulted in loss of power to the '2B' RPS distribution panel.
Various automatic Primary Containment Reactor
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Vessel Isolation Control System isolations occurred due to the loss of power. Also, Reactor Enclosure and Refuel
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Floor ventilation systems isolated and the Reactor Enclosure Recirculation System and the Standby Gas Treatment Systems started. Both reactor recirculation pumps also tripped. All isolations were reset and systems were returned to service promptly and there was no adverse impact on plant operations. The cause of the loss of power was a bad electrical connection on a card in the
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static inverter. The failed card was replaced on December 26, 1989 and the system has operated properly since that time.
The inspector had no further questions, at this time, concerning this event.
9.0 post Accident Sampling System Environmental Qualification The purpose of the inspection was to review the environmental qualification status of the equipment associated with the post accident sampling system on Unit 2.
For his review, the inspector selected the sampling system
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isolation valves and the containment high range radiation monitor. The inspection consisted of a review of the applicable qualification pachages
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and a plant walkdown to ensure that the equipment installation is enveloped by the tested conditions.
9.1 Document Review The sampling system isolation valves are ASCO solenoid valves and are used to isolate the non-safety related sampling station from the safety related system or equipment with which they interface. These valves close automatically in the event of a loss of coolant accident (LOCA).
However, they can be manually opened from the control room, following the accident, for the required samplin gr L
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Evaluation of the applicable qualification package, PEco No. E124, revealed no deficiencies.
In particular, the valves selected for the physicel review, HV51-2F079A and HV51-2F080A, are located in a zone which is radiation harsh only.
The containment high range radiation monitor used at Limerick, Unit 2,
is manufactured by General Atomics and is used for primary containment
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post LOCA radiation monitoring. Its primary function is that of providing the signal required for control room indication, recording-and alarming of radiation levels.
Evaluation of the applicable qualification package, PECo No. E58, revealed an apparent discrepancy relative to the qualification of the RD23 detector connector.
The discrepancy resulted from a statement in the report which appeared to exclude qualification of the connector, even though the qualification report included documentation to the contrary. The discrepancy was immediately corrected by the manufacturer with a letter of December 13, 1989.
The coaxial cables used by the licensee for the interconnection of the high range radiation monitoring system is manufactured by the Rockbestos Company. As a result of potential deficiencies identified in the insulation resistance of the cable, Sorrento Electronics, the manufacturer of the radiation monitor, issued a 10 CFR Part 21 report.
Accordingly, under high temperature conditions, the insulation resis-
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tance of the cable could drop enough to reduce the accuracy of the monitoring instrument below that recommended in Regulatory Guide (RG) 1.97.
In response to Sorrento Electronics' report, the licensee performed an analysis to show that under the expected operating conditions the accuracy of the instrument would be well within the specified accuracy. The analysis also showed that in the event of a
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low radiation condition, less than 8.2 Rads / hour, concurrent with high temperature, 340 degrees F, the accuracy of the system would be outside the limit set by R.G.1.97, "within a factor-of-two over the entire range," 1. e, 1 R/Hr to 10E7 R/Hr. The licensee recognized that under the stated conditions, the instruments involved would not meet the R.G. 1.97 recommendations.
However, in its analysis, the
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licensee did not consider credible an event which would produce LOCA I
temperatures and radiation levels below the calculated 8.2 R/Hr.
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As a result of a previous commitment to reevaluate the accuracy of the high range radiation monitors at the Peach Bottom Atomic Power
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Station, PECo agreed to concurrently reevaluate the installation at the Limerick Generating Station. This item is unresolved pending the NRC review of the analysis results (50-353/90-02-01).
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9.2 Hardware Inspection
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Inspection of isolation valves HV-51-2F079A and HV-51-2F080A revealed
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adequate installation. However, review of the associated termination
boxes resulted in the discovery of an open cover. The condition was reported to the licensee which immediately conducted an investigation.
but was unable to determine its cause. Apparently, no work had been
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done on the equipment involved following the plant startup.
Even-tually, PECo attributed the incident to craft oversight, perhaps while conducting system testing.
In the particular area, the open junction box did not constitute a safety hazard since the zone is only radiation harsh. Nonetheless, the licensee issued MRFs No. 8910694 and 8910697 to inspect all junction and terminal boxes within the drywell and the containment enclosure for missing or loose clips.
No other bores were reported open. Based upon the results of the licensee's inspec-tion, the issue of the open box was considered to be an isolated case and was, hence, closed.
Inspection of the installation of the RD-23 high range radiation detectors revealed that the cable / detector connector assemblies associated with RE-026-291A had not been sealed in accordance with the instructions provided in the qualification report and used by the manufacturer during the qualification testing of the device.
Proper sealing of the assembly is critical to the operation and accuracy of the instrument.
Identification of the condition to the licensee resulted in an immediate MRF to correct the anomalous instal-lation. The installation instructions used in the MRF reflected the requirements of the qualification report.
The inspector examined the other three installed radiation detectur to determine if they had similar problems. The inspector found they were all properly installed.
Subsequent evaluation of the finding by the licensee determined that the root cause of the occurrence was the omission of Raychem's in-structions for heat shrink tubing with EQ cable connectors from Procedure No. E-1412. This procedure was appropriately revised.
In addition, the licensee prepared a new procedure, 1C-11-00265, which
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provides detailed instructions for the proper sealing of the connector.
The inspector found these corrective actions adequate. However, installation of a device in an untested configuration without adequate analysis constitutes a violation of 10CFR 50.49, paragraph (f), which requires that each item of electric equipment important to safety be qualified by testing or experience with identical or similar equipment under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable (NC4 50-353/89-32-02).
I Based on the root cause analysis, the fact that this appears to be an isolated case and the corrective actions already performed by the licensee, this issue is technically closed and no further actions or response to the violation are required.
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10.0 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, deviations or violations.
One unresolved item was identified and discussed in paragraph 9.1.
11.0 Exit Interview (30703)
The NRC resident inspectors discussed the issues in this report with the licensee throughout the inspection period, and summarized the findings at an exit meeting held with the site Vice President, Mr. G M. Leitch and members of his staff on February 2, 1990. No written inspection material was provided to licensee representatives during the inspection period.
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NRC Form 766 lj. S. NUCLEAR REGULATORY COMMIS$10N l
Principal Inspector:
Kenny, Thomas
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d Reviewer: L. Doerflein
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INSPECTOR'S REPORT Office of Inspection and Enforcement Inspectors:
Transaction
_ Docket #/ Inspection #/ Seq #
_
T. Kenny Type.
,
_
L. Scholl
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I-Insert 05000352 90-02 M. Evans
A. Della Greca M-Modify
[05000353 90-02 i
D-Delete
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R-Replace
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[7(4d,$eaf1#g.
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Licensee / Vendor:
o Philadelphia Electric Co.
Attn: Mr. C. A. McNeill, Jr.
J gy p Executive Vice President - Nuclear
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Correspondence Control Desk P.O. Box 195 Wayne, PA 19087-0195 l
Period of Inspection: _ Inspection Performed By:
1-Regional Office Staff _ Organization Code of Reg.:
From To Region Division Branch
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- 2-Resident Inspector I
B B
01/01/90 01/29/90 [ 3-Performance Appr. Team [
-Other-
_
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l Regional Action:
Type of Activity Conducted (* one only):
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_
1 - NRC Form 591
- 02-Safety 07-Special 12-Shipment / Export
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l 2 - Regional 03-Incident 08-Vendor 13-Import
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Office Letter [ 04-Enforcement 09-Mat Acet.
14-Inquiry
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l 05-Mgnt. Audit 10-Plant Sec.
15-Investigation
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06-Mgnt. Visit 11-Invent. Ver.
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Total No. of Enforcement Report
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Violations and Conference Contains
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Deviations:
Held:
2.790
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A=0
~Information:
[
B=1
[
[
Inspection Findings:
_ Letter or Report Transmittal A
B C
D Date
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X Clear X
- Violation
[NRCForm591orRegion
- Deviation Letter Issued:
- Violation & Deviation [ReportSenttoHQfor Action:
_
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NRC Form 766 - Continued MODULE INFORMATION Record /
Direct Percenta9e Status Module Module No.
Insp. Hours Complete Followup s
............
...........
..........
......
........
Unit 1 576753
100 561726
100
~ 562703
300 571707
100 571710
100 590712
539702
540703
583750
UNIT 1 TOTAL 155 Unit 2
.530703
100 561726
100 562703
100 571707
100 571710
100 590712
539702
540703
435501
100 472301
100 472400
100 472532
100 537700
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Unit 2-Total 122 Unit 1/2 Total 227 i
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e INSPECTOR'S REPORT (Continuation)
Docket No. 05000353 Report No. 90-02 Seq. A Module No. 37700 l
Violation Severity IV j
i As result of the inspection conducted on December 14, 1989, a violation of NRC i
requirements was identified.
In accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C) the particular violation is set forth below:
l 10 CFR 50.49, paragraph (f) requires that each item of electric equipment important to safety must be qualified by testing or experience with
identical or similar equipment under similar conditions with a supporting
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analysis to show that the equipment to be qualified is acceptable, i
Contrary to the above, on December 14, 1989, the installed configuration
of the Raychem heat shrink tubing associated with the cable / detector connector assembly of the High Range Radiation Monitor RE-026-291A on Unit 2 was found not to conform with the tested configuration. No similarity analysis had been performed by the licensee to justify the acceptability of the installed configuration.
This is a severity level IV Violation (Supplement I)
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NRC Form 6 Rev. Dec. 86 0UTSTANDING ITEMS FILE SINGLE DOCKET ENTRY FORM i
Docket Numbers:
50-352/50-353 Originator:
Kenny, Thomas Reviewing Supervisor:
Doe flein U.7
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Report Hours Report Hours 50-352 1.
Operations
50-353 1.
Oper$tions
2.
Rad-con
2.
Rad.on
~3 3.
Maint/Sury
3.
Mafnt/Sury
"'ll
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4.
Emerg. Prep.
_0 4.
Emerg. Prep.
_-
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5.
Security
_3 5.
Security-
_3 6.
Eng / Tech.
6.
Eng / Tech.
Support
,15 Support
_23 7.
Safe Asst /QV
7.
Safe Asst /QV
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8.
Startup
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NRC Form 6 Rev. Dec. 86
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OUTSTANDING ITEMS FILE SINGLE DOCKET ENTRY FORM
Docket Numbers:
50-352 and 50-353 Originator:
Kenny, Thomas Reviewing Supervisor: Doerflein Y
ce t
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Item Num. BType ginspection Number BSALP Area BOI Area 5 Action Due BDue Key OP 90-02-01 UNR 50-353/90-02 EQ SME 3/31/90 Resp Sec. GInspector's Name BDate Opened BDate Updated Rupdate Insp.
PSS Della Greca 12/22/89 Modifier / Closer:
Descriptive Title: Accuracy of High Range Radiation Monitor Item Num. BType gInspection Number BSALP Area 301. Area BAction Due 50ue Key OP 90-02-02 NC4 50-353/90-02 EQ SME Resp Sec. 3 Inspector's Name 3Date Opened BDate Updated 30pdate Insp.
PSS Della Greca 12/22/89 12/22/89 90-02-C Modifier / Closer:
Descriptive Title: Unqualified Installation of Raychem Heat Shrink Tubing Item Num. BType gInspection Number BSALP Area BOI Area 5 Action Due 30ue Key OP L
88-20-03 UNR 50-353/90-02 l
Resp Sec. 3 Inspector's Name 30 ate Opened 3Date Updated gupdate Insp.
12/22/89 90-02-C Modifier / Closer:
Scholl j.
Descriptive Title:
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