IR 05000352/1990020
| ML20062B792 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/12/1990 |
| From: | Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20062B790 | List: |
| References | |
| 50-352-90-20, 50-353-90-19, NUDOCS 9010260145 | |
| Download: ML20062B792 (28) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No Docket No c
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License No NPF-39 NPF-85 Licensee: Philadelphia Electric Company Correspondence Control Desk P.O. Box 195 -
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Wayne, Pa ' 19087-0195 Facility: Limerick Generating Station, Units 1 and 2 . Inspection Period- August 13 - September 16,1990
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inspectors: T. J. Kenny, Senior Resident Inspector I L. L. Scholl, Resident Inspector M. G. Evans, Resident Inspector 'i Approved by: OaJhta 6%.2 10/I 90- - Lawrence T. Doerflein, Chief '
.Date Reactor Projects Section No. 2B f Division of Reactor Projects
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Inspection Summarv: . This inspection report documents routine and reactive inspections dunng ~ U day and backshift hours of station activities including: plant operations; radiation protection; surveillance and maintenance; emergency preparedness;' security; engineering and technical l support; and safety assessment / quality verificatio ! i
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EXECUTIVE SUMMARY
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! Limerick Generating Station ! Report No. 90-20 & 90-19 Plant Ooerations The supervision of the September 10 scram recovery by the shift manager and the shift supervisor was excellent. Plant procedures were properly utilized and communications among the control room staff were viewed to be very good (Section 1.2). > An inadvertent Engineered Safety Feature (ESP) isolation occurred as a result of inadequate ; communications between a shift supervisor and a reactor operator (Section 1.2), t
Maintenance and Surveillance 1
Two inadvertent ESF isolations occurred due to personnel errors during conduct of surveillance i testing (Section 1.2).
, Engineering and Technical Support Philadelphia Electric Company (PECo) developed a good plan for the disposition of the N2H recirculation pipe to nozzle safe-end weld indication (Section 5.2).
Safety Assessment and Ouality Verification , PECo voluntarily shutdown Unit 2 to address overall electro-hydraulic control system (EHC)
- piping problems and to accomplish repairs. This action was positive and appropriate'to avoid
- future unnecessary challenges to safety systems caused by EHC piping failures (Section 1.3).-
l l PECo has strong programs for dealing with the identification and disposition of fraudulent , l materials and for purchasing parts from reputable vendors with built-in assurances against buying ' fraudulent materials (Section 6.0).
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i TABLE OF CONTENTS __ EARC - Executive Sum mary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i Plant Operations Review (71707,.93702) . . . . . . . . . . . . . . 1;
. Operational Overview ....................... I Reportable Events . . . . . . . . . . . . . . . . . . . . . . . . l '- Electro hydraulic Control System Discussion .........4 Surveillance /Special Test Observations (61726, 71707) . . . . . . 6 I Maintenance Observations (62703, 71707) ............. 6 Emergency Preparedness (7170i; ................... 7 Engineering and Technical Support (71707,60705,37700,37701) .7 Design Modifications . . - . . . . . . . . . . . . . . . . . . . 7 Recirculation Pipe Disposition . . . . . . . . . . . . . .. . 7 Electro-Hydraulic Control System (EHC) . . . . . . . . . . 9
' Followup of Bulletins, Information Notices and Generic l Ixtters (92701) ..........................,.. 9 ,
l Review of Licensee Event and Special Reports (90712,92700): 11 Unit 1................................. 11 Unit 2............................... 12 - i Review of Control Room Habitability Requirements (92701) . . 13 ; Followup of Previous Inspection Findings (92701,92702)L . . . : 14
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1 Exit Interview (30703) . .. . . . . . . . . . . . . . . . . . . . . . . . 16 i l l 'l ! . .
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a 9 DETAILS Plant Ooerations Review G1707. 93702) ! Ooerational Overview 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 inspections, discussions were held with operators, health physics (HP)'and i instrument and control (I&C) technicians, mechanics, security personnel, supervisors and I 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. During this , period,29 hours of backshift inspection was conducte ' At the start of this report period both units were operating at 100% powe On September 7, Unit I was shutdown to begin its third refueling outage. Reactor power-- was reduced to 30% and then the reactor was manually scrammed. Modifications to be- * implemented during the outage and reviewed by the inspectors are discussed in Section 5.1 of this repor On August 20, Unit 2 was shutdown due to a leak in the electro-hydraulic control system (EHC) piping to the number 4 turbine control valv The Limerick Station has _
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encountered a series of EHC system leaks so this voluntary shutdown was taken in order to address overall EHC system problems and to accomplish repairs. Refer to Section of this report for further details. Following repairs, the reactor was made critical on-
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August 26 and returned to 100% power on September On September 10, Unit 2 automatically scrammed from 100% power due to a spurious: trip signal from a defective temperature " read" switch.- Refer to Section 1.2 of this report
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for additional details of the shutdown. Following repairs to the switch the u' nit was returned to service and reached 100% power on September 1 .2 Reportable Events Unit i On August 13, a Reactor Water Cleanup (RWCU) system isolation occurred due to the RWCU regenerative heat exchanger . room temperature exceeding the 117 degrees !- Fahrenheit (F) setpoint. The actual temperature reached 119 degrees F. Both the inboard and outboard RWCU suction isolation valves closed as' designed. The .temperatu're
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increase was caused by steam leakage past the seats of two normally closed drain valves in the RWCU system. The valves were repaired and the system returned to operatio j ' There were no adverse effects on plant chemistry and all parameters were maintained within the plant technical specification limit f t?
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On August 28, a half scram and other various half isolations occurred due to a loss of > power when an instrument technician inadvertently shorted a 24V power supply, resulting . in a blown fuse. Instruments which provide input to the Reactor Protection System (RPS) , and Nuclear Steam Supply Shutoff System tripped on loss of power. This event had no . 1 significant impact on plant operations. The blown fuse was replaced and the logic was' i reset within 18 minute ~ On August 31, PECo reported.that the plant was in a condition which could hav compromised plant safety in a Moderate Energy Line Break (MELB)/High Energy level l Break (HELB) accident. Operations personnel identified that a section of diamond plate - _
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flooring had been removed from the floor of the safeguards piping room. ;The diamond - plate had been removed by construction personnel on August 27,- to facilitate installation : of a modification. -In the event of a MELB accident in Room 309, the plate is designed ; y to prevent flooding the Rt.sidual Heat Removal (RHR);and. Reactor' Core Isolation: j
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Cooling (RCIC) rooms beneath the plate. This plate was reinstalled by 11:59 p.m. on - August 30. In addition, several other diamond plate sections located in Room 309 were : i restrained from opening due to scaffolding installations which had been erected on the top - of the plates. These plates perform a steam relief function in the event of a steam break, and would have been unable to perform their intended design function for a'HELB accident in the High Pressure Coolant Injection (HPCI), RCIC or RHR rooms. - The - scaffolding restraining the steam relief floor plates was removed at 9:00 p.m on' August , 31. PECo's actions to prevent recurrence include a new requirement to ' write an : Engineering Work-Request (EWR) prior to opening floor plates, blow out panels'and hatches in order to determine appropriate prerequisites. In addition, the administrative _
- procedure for cor. trolling scaffolding will be revised to specifically address scaffolding constructed in the vicinity of floor plates and blow out panel ,
On August 31. PECo concluded that with the plate removed and/or steam relief plates restrained, a MELB/HELB accident may have resulted in the loss of equipment necessary to safely shutdown the plant.' A detailed engineering: evaluation of the potential i R consequences is in progress and will be included in the LER associated with this even The inspector found the actions taken to prevent recurrence to be appropriate and wil a ! review the engineering evaluation further upon issuance'of the LE ' Unit 2 4 On August 31, an inadvertent RCIC inboard steam line isolation and turbine trip occurrsd due to personnel error during a surveillance test. The I&C technician performing the test
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missed several steps in the return to normal section of the surveillance test which resulted ' in wire 15'on the RCIC pipe area high temperature transmitter, 'ITS-049-2N6023R, not a
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being reconnected before the-temperature bypass switch, B21B-S5C, was returned to
- normal. . The I&C technician reconnected the wire and the RCIC isolation was properly
,- reset. .The cause of the error was' the technician's. lack of attention to detail while L performing the surveillance test.
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l 3 On September 6, during performance of a surveillance test on the RWCU system, an IAC - technician lifted the wrong lead which resulted in an isolation of the RWCU system. The test being performed affected the outboard system logic. The technician lifted a lead in l the inboard logic causing the inboard isolation valve (HV-44-2F001) to close. Th ' l RWCU system was placed back in service within 10 minutes of the isolation. ;The cause - ! of the error.was the technician's failure to identify the correct lead as required by the implementing procedure. Corrective. action for this event and the August 31 event i discussed above included counseling of the individuals involved and dis:ussion of.the i events at an I&C all hands meeting on September 14. The inspector fount the licensee's' corrective actions to be appropriate and had no further question t
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On September 10, an automatic RPS' actuation occurred resulting in a Unit 2 reactor scram. The scram was caused by a MSIV isolation on high steam t.innel temperature initiated by a spurious trip signal from a defective Riley " read"_ switen. One temperature ' - circuit was in bypass at the time due to surveillance testing. An operator, taking readings - during routine rounds, turned the Turbine Enclosure Steam Tunnel Temperature Switch to select a different temperature monitor. The steam detection system temperature " read"- , switch for the selected temperature monitor was defective and resulted in a spurious trip signal. This signal, with the other channel in test, completed the logic for the MSIV isolatio Immediately following the scram the reactor water level decreased to -46 inches and then was restored to normal using RCIC. Various system isolations also occurred due to the - ! low reactor vessel level which normally occurs during a turbine trip transient. The isolations were subsequently reset as part of the transient recovery. All control rods fully _ inserted and there were no offsite releases.- The inspector observed the actions of the
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control room operators after the scram. The supervision of the scram recovery by the - shift manager and the shift supervisor was excellent. Plant procedures were properly - utilized and the actions of the reactor operators were closely monitored and concurred in by the shift supervision. Communications among the control room staff were very. good and resulted in the shift supervision being constantly updated on the status of key plant-l parameters and the lineup of plant systems utilized in the transient recovery. The (
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' inspector reviewed Procedure GP-18, " Scram /ATWS Event Review," and determined that . several minor equipment problems encountered during the transient had been properly ' evaluated and dispositioned prior to restart. The inspector also noted that, as part of the corrective action, the licensee issued a Shift Training Memorandum which defined a
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program prohibiting any surveillance testing requiring initiation of a single channel of the primary containment and reactor vessel isolation control system or the reactor protection system while daily operator readings nre being taken. This program will be formalized by incorporation into the Operating Manua On September 16, following troubleshooting of the HPCI system steam line differentialL pressure high transmitter (PDT-055-2N057B), a HPCI outboard steam'line isolation occurred. The outboard HPCI steam isolation valve (HV-055-2F003) closed when the - i
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valve was reenergized prior to resetting the isolation system logic. The' isolation signal was immediately reset and the valve was reopened.- The cause of the isolation' was a
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communication problem between the shift supervisor and the reactor operator. The shift supervisor told the reactor operator to reset the logic and then reenergize the. valve. The , reactor operator did not adequately repeat back the instructions and forgot to reset the__ l isolation system prior to reenergizing the valve. Both individuals were counseled on the i importance of adequate communications. ' 'Ihe inspector found the licensee's corrective actions to be appropriate and had no further question j
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j i The above events were reported to the NRC via the Emergency Notification Syste _
(ENS) and the root cause analysis and corrective action will be reviewed further upon
ieuance of the Licensee Event Reports as part of the routine inspection progra ! Severs' of the safety system actuations discussed above were due to personnel error. The inspector noted that,. in response to previous problems with personnel errors and procedutal violations, PECo began an evaluation to determine actions to resolve these , weaknesses. Based on the above, continued management attention in this area is - warrante .3 Electro-Hydraulic Control System Discussion . I i Philadelphia Electric Company's (PECo) problems with the electro-hydraulic control (EHC) system piping began on Unit 1 in 1985, when an instrument tube and~ support " broke at the EHC reservoir. The break had been attributed to an overstressed suppor , The tubing and support were subsequently repaired, however, the fitting broke agai .
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The tubing was then installed without the support and the failure did not recur. 'In'1987, '! the tubing to the #3 turbine control valve broke at a tee connection. ! This break was -
attributed to weld failure caused by a lack of fusion with fatigue due to tubing vibratio In October 1989, another weld at a fitting to the #2 turbine control' valve failed. : This failure was temporarily repaired using " Leak Repair":(a method Lof installing a box around the faulty fitting and injecting it with an approved substance that solidifies and plugs the leak) and will be repaired permanently during the current Unit:1 refueling- _ outag . Unit 2 experienced similar problems with the EHC System'in March and June 1990,' and most recently in August 1990. Again weld failures at fittings were identifie Some of these EHC leaks.have led to challenges of the reactor protection system by' , causing unit scrams, while others have been discovered by the operators and followed by orderly power reductions or shutdowns to facilitate repairs.' An additional concern wa I identified when EHC fluid was introduced into the Unit 1 reactor coolant system and
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potentially contributed to the fuel damag'ewhich occurred during the second operating - . cycle. With these two identified concerns in mind, PECo decided to shutdown Unit 2 on August 20 following identifiestion of a leak'in the EHC piping'to the numberf4 l
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u turbine control valve, in order to resolve the EHC piping leakage problem; The resident inspector attended a PECo meeting where the EHC system problems ar.d the identified repairs were discussed. These items are summarized below:
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The problem with the failed welds has been attributed to the weld joint design of the tubing to the type of fittings used. The thin wall tubing does not weld easily: to the heavy wall fittings because of the critical heat requirements necessary to cause melting of the fitting without burning through the tubing wall. Although ' no fittings have been cut out of the system to date, the weld joint design has been . -! the most probable cause of the weld. break t
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The EHC system experiences pressure pulses, during the command signals to the - ,
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turbine control valves, while the turbine is operating. These pressure pulses may - add to the vibration of some welds. : The installation of surge tanks could dampen ' ' j out these pressure pulse Another system design utilizing stainless steel piping could be used. This system . U l would be heavier and more rigid and would require different hanger arrangements : , and ficxible hoses where'the system connects to<the turbine control and stop i
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valves. This system would be more easily weldable with a better joint desig However, lead times for replacement parts and system design would take months 1
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PECo determined that they had two options to pursue during the Unit 2 chutdow ) Fabricate a new pipe run with new fittings and tubing with extra attention given to weld design and welder performance or 2) Leak Repair the fittings (total 11).
l l PECo decided upon Leak Repair of all fittings in the system (further discussed in Section j 5.3 of this report) in lieu of refabrication of the system at this time. System refabrication : l would require a longer time to complete and flushes would be necessary, extending the time off line. Also, the uncertainty of the tubing- fitting weld configurations is still in l question as to'whether they would be successful, even though more control ~would be exercised with welders and weld qualificatio +; - The Leak Repair of the fittings was completed and the teactor returned to' 100% power - on September 5. The redesign of the entire system will be reviewed for installation on Unit I during the refueling outage beginning in September 199 ~ Because of the intrusion of EHC fluid into the reactor coolant system on. Unit- 1, PECol has been cautious in preventing EHC intrusion into the reactor coolant and minimizing _ radwaste releases. EHC fluid could not be detected by:the original Total Organic .
- Carbons (TOC) analyzer so a new method utilizing infra red detection, Fourier Transform M I
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l_ Infra Red (FTIR), is now being u.ed by the chemistry technicians to routinely monitor : $ ' for EHC in the floor drain collection system. The. concentration limit suggested by GE' is 400 ppb. The goal set by the station is 200 ppb. If the floor drain collection system - water concentration is below the 200 ppb detection limit then the processed water is' returned to the condensate storage tank. If the concentration is greater than 200 ppb then j
' the water is discarde '
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~l Initially Peco treated the EHC problems as isolated occurrences and corrected them on a case by case basis. However, PECo has recently taken the approach that the problems I are design related and has outlined steps to rectify them. This action, . including .
voluntarily shutting down Unit 2, to address the overall EHC problems is seen as being very positive and oriented towards safet , Surveillance /Soecial Test Observations
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During this inspection period, the inspector reviewed in-progress surveillance testing a well as completed surveillance packages'. The inspector verified that surveillances were ; i performed in accordance with _ licensee approved . procedures, plant technical . specifications, and NRC Regulatory Requirements.. The' inspector also' verified;that i instruments used were within calibration tolerances' and. that qualified technicians - i performed the surveillances. No problems or concerns were noted by'the inspector 't Specific surveillances reviewed during _the inspection of Control' Room Habitability requirements are discussed in Section 8.0 of this repor .0 Maintenance Observations-The inspector reviewed the following safety related m'aintenance activities to verify that _ i 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- .. l licensee's QA progra l MRF 9003094 Install Ixak Repair on EHC Fi ting MRP 9004109 - Adjust Spring Hangers-M'RF 900412 Adjust Spring Hangers-MRF 9004515 Installation of Leak Tight on EHC Fittings'- MRF 9001785 Install Clamp on I2aking Tee Connection MRF 9001892 Reset Spring Cans to New Cold Settings ~ t
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No problems or concerns were noted by the inspectors.- i q l !
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7 l l Emergency Prenatedness On August 16, PECo was granted an exemption from the schedular requirements of - Section IV.F.3 of 10 CFR Part 50 Appendix E to perform a biennial full participation onsite/offsite emergency preparedness exercise for the Limerick Generating Station (LGS) - , during 199 I
1 Since 1984, PECo has been conducting the required biennial full participation emergency , exercises for both LOS and Peach Bottom Atomic Power Station during the same yea l This has caused logistical and resource utilization difficulties, considering the number of ; ! federal, state and local governmental agencies involved in a full participation exercis ! Therefore, the exercise, originally scheduled for the week of September 17,1990, will , be conducted in February 199 ,
! Engineering and Technical Support Design Modifications
i On September 7,1990, the resident inspectors met with PECo engineering managers and , engineers to discuss certain modifications that are being installed during the Unit 1 third
- refueling outage. The modifications listed below were discussed and no concerns were -
i identified thus far. Inspection will' continue during their iinplementation to . verify conformity with NRC regulations and PECo commitments.
i Modification l Number Title: ' 5994 Reactor - Core: Isolation J Cooling (RCIC) Power i Supply Transfer Switch i l 5995 High Pressure Coolant injection (HPCI) Emergency .
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Shutdown Switch - . j , 5998 Reactor Water. _ Cleana upf l(RWCU) Bypass , i . Disconnect Switch . .I U 5085 Rosemount Transmitter Replacement - 5791 New Low Pressure Coolant-Injection'(LPCI). Min' ! ' Flow Orifices? 5816 Control Rod Drive / Hydraulic Control-Unit (HCU) , Header Check; Valves - 6101 Main Steam Relief Valve (MSRV) Replacement l
' - Recirculation Pipe Disoosition a
The inspector attended an PECo Engineering meeting on August 29,1990, at which were ' R discussed technical issues related to the disposition of the.N2H recirculation pipe to r ! ! i j
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8 , nozzle safe-end weld indicatio The meeting. scope included presentations of technical and schedular.information,1 1 alternatives for disposition of the indication, technical discussion of the mechanical stress : , improvements process (MSIP), description of weld overlay process,land' schedule for : 1 , i implementation of the selected disposition approach,
Attached to this report (Attachment 1) are copies ofinformation presented at the meeting 9 including the meeting objective, presentation outline, N2H nozzle drawing, flaw extent : , indication chart, disposition algorithm,4 N2H indication dimensions - with probable, ! disposition, and N2H nozzle to safe-end weld examination schedule... Also included is a ; list of attendees at the meetm ,
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Discussed were three possible dispositions of the weld indication being considered by; g , PECo: (1) to leave the indication as is, (2) to apply MSIP to the weld indication region, _ t
. and (3)to apply overlay welding to the nozzle outside diameter (OD) in the region of the
, weld indication. The disposition selected'will depend on the extent of crack propagation
- (or lack of propagation) measured by ultrasonic testing (UT) of the nozzle safe-end during -
, the Unit I third refueling outag Although the original indication has not been ascertained to be an_ intergranular' stress corrosion crack (IGSCC), it has been conservatively assumed to be of that type. lThe .
' possibility exists for the indication to be from either a defect from original fabrication or - . previous repair, or a- UT reflection caused by. the 'c omplex nature of the'weldment-material combination ' . The original flaw indication in the 1.4 inch thick nozzle wall was determined by UT to be approximately 18% through-wall over seven inches of circumferential length, with a short section of the indication approximately 29% through-wall. It was estimated by ( . . means of a conservative crack propagation computation that this indication could penetrate
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l to 71 % through-wall over one operating cycle (18 months).
l At the end of this report period there was a specialist NRC inspector on site to observe
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the inspection of the nozzle safe-end. His observations and findings will be presented in
- mspection reports 50-352/90-22 and 50-353/90-2 t
' Subsequent to the specialist inspection, ultrasonic testing data indicated that the crack had i grown. Final disposition of the indication will be the subject of a meeting bemeen the NRC and PECo scheduled for October 5,1990, and will be reviewed in a future q t inspection.
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9' Electro-Hydraulle Control System (EHC) The inspector reviewed activities regarding the repair of the Unit 2 EHC piping syste Three Non-Conformance Reports (NCRs) have been issued since June 5,1990 to resolve i identified leaks at weld joints in the EHC syste The inspector reviewed NCRs L900112, L90157 and L90167, issued on June 5, August - 3 and August 21,1990 respectfully. For each NCR, Leak Repair (as discussed in Section 1.3 of this report) was utilized to repair the leak The inspector concluded that all the repairs to the EHC System were conNeted in ! accordance with station approved procedures and that.the repairswere v sthin code requirements as outlined in the NCRs. All three NCRs concluded that the b:ak Repair
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to the fittings was a temporary repair and would need to be reevaluated where the unit was-shutdown for refuelin .0 Followuo of Bulletins. Information Notices and Generic Letters Licensees receive information, on a continuous basis, from the NRC in the form of bulletins, information notices and generic letters. Some of this correspondence requires a reply to the NRC while some may be provided for information only and thus is handled by the licensee in other ways. The purpose for this inspection was to access PECo's program for the handling of the information contained'within the correspondenc This inspection particularly_ centered around the following correspondence, all related to ' questionable materials purchased or shipped by vendor Bulletin 87-02 " Fastener Testing tol Determine Conformance with Applicable Material Specifications" (Supplements l'and 2)
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Bulletin 85 05 " Nonconforming Materials Supplied by Piping Supplies, Inc. at Folsum, New Jersey and West Jersey Manufacturing i Company at Williamstown,- New Jersey" (Supplements 'l '- and2)
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Bulletin 8810 Nonconforming; Molded Case Circuit Breakers"
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. I Information Notice " inappropriate Application of Commercial Grade - > 87-66 Components" Information Notice " Questionable Certification of Class 1E 88-19 Components" , l
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-Information Notice " Inadequate Licensee Performed Vendor Audits"
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88-35 l ; Information Notice -" Licensee Report of Defective Refurbished - 'I 88-46 Circuit Breakers" (Supplements 1, 2, 3 and 4); } i Refurbished ~ Information Notice " Licensee Report of Defect ve ] 88-48 _ Valves" (Supplements 1 and 2) I l Information Notice "Potentially Substandard Valve Replacement -- ! 88-97 Parts" (Supplement 1) i Information Notice " Questionable Certification of Fasteners" 89-22 Information Notice "Metalciad, I.ow-Voltage Power Circuit Breakers-89-45 Refurbished with' ' Substandard Parts - (Supplement-1)" Information Notice " Questionable Certification of Material Supplied 89-56 to the Defense Department by Nuclear Suppliers" - 3 i Information Notice " Suppliers of Potentially_ Misrepresented - ;
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89-59 Fasteners"
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Information Notice '"Possible Indications of'Mispresented Vendor l 89-70 Products" , i ! Generic Letter " Actions to Improve the Detection of Counterfeit L 89-02 and Fraudulently' Marked Products"= -! l The inspectors' review of PECo's actions confirmed that NRC correspondence 1) was - .
reviewed for applicability, 2) received proper distribution to the appropriate personnel at ; I the corporate and' site levels and 3) appropriate corrective actions were implemented,' some of which are outlined belo ,
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PECo has incorporated, into their Materials Management Training Program, information - from NUMARC - (Nuclear Management : and Resources Council) on " Identifying = Characteristics of Surplus or Rebuilt Valves" and. EPRI-(Electric Power Research
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Institute) on " Guidelines for Replacement and Receipt of Items for Nuclear Power Plants (NCIG-15)," final report of May 1990.1 Also incorporated into training'are fraudulent l- awareness traimng sessions that include participation by the QC departmen . . .
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-11 1 The program for dealing with fraudulent materials currently is in place which: 1) 1 addresses and/or utilizes " alert lists".to identify vendors who supply fraudulent or I counterfeit items or documents, 2) performs vendor audits and 3) performs commercial 1 grades survey q q
Generic letter 89-02, " Actions to Improve the Detection of Counterfeit and Fraudulently a Marked Products" was also reviewed by the licensee. This letter encourages licensees to: s Involve engineering in the procurement and product acceptance process, particularly when commercial grade procurements are involved. Normally, this includes (a) specification development for products to be used in the plant (b); determination of critical characteristics to be verified during product acceptance (c) determination of testing requirements and (d) evaluation of test results, e Strengthen the source inspection, receipt inspection and testing program . Implement a sound commercial grade dedication program meeting the intent of the methods described in EPRI NP-5652 " Guideline for the Utilization of Commercial-Grade Items in Nuclear Safety-Related Applications (NCIG-07)," as modified by Generic Letter 89-02.. l l The inspector had discussions with PECo management and'has verified by review of documentation that PECo has addressed the recommendations listed in Generic Letter 89-02 and has a strong. program for dealing with the: identification andl disposition o . fraudulent materials as well as a program for purchasing parts from reputable vendors . with built-in assurances against buying' fraudulent materials. The inspector;had no - concerns regarding PECO't actions for dealing with fraudulent material in particular, nor ^ with the handling of and disposition of NRC correspondence in ' genera l 7.0 Review of Licensee Event and Soccial Reports L The following Licensing Event Reports (LER) or Special Reports were reviewed by the inspector. and determined to have accurately ' described-the events and to have'been properly addressed for corrective or compensatory action:
7.1 Unit 1 l 1 l L , LER 1-90-015, event date August 13, 1990
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Reactor water cleanup system isolation due to elevated regenerative heat exchanger room - temperatures resulting from seat leakage past two manual drain valve i
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LER l-90-016, event date August 15,'1990
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On August 15, PECo received an internal allegation of falsification of records involving Technical Specification fire doors. The allegation' implied that the fire doors were not . A being verified closed as per technical specifications and therefore the limiting condition - for operation could not be satisfied. Upon investigation into the allegation PECo found it to be true and the responsible party was terminated from the site. Another instance was - I also identified resulting in a second individual also being terminated. The supervisor was counseled on the importance of performing audits and evaluations on the accuracy of the surveillance of fire protection system R
- Monthly Operating Report for August 1990, dated September 7,1990 7.2 Unit 2 LER 2-%011, event date July 13,1990 Unit 2 Reactor Enclosure Secondary Containment Isolation due to the failure of ano instrum:nt air line to the ventilation fan controllers. When the instrument air line to the exhaust fans failed, the blade pitch went to the minimum position resulting in an increasing pressure in the reactor enclosure. Normally the fans would automatically trip
> when a positive pressure of four inches of water is reached and the blow out panel would actuate only if pressure continued to rise to_ seven inches of water. During this event the l' blow out panel opened prematurely and below the pressure at which the fans would have - automatically tripped. The cause for the premature actuation of the blow out panel is the subject of an ongoing engineering evaluation. The results of this' evaluation will be provided in a supplement to this LE This event was initially reviewed and documented in Inspection Report 50-352/90i18 and i- 50-353/90-17, Section 1.1, however, the event was inadvertently included under the Unit
- I section of the repor LER 2-90-012, event date July 15, 1990 i
' Reactor scram caused by ~a main turbine stop valve closure resulting from a low condenser vacuum trip of the main turbine. The low condenser vacuum was caused by the failure of a turbine bearinF ube l oil drain pipe which passed through the main > condenser. This event was preiiously reviewed and documented in Inspection Reports 50-352/90-18 and 50-353/90-17, Section Monthly Operating Report '.or August 1990, dated September 7,1990-No additional concerns were identified upon review of the above listed report . U- -
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- Review of Control Room Habitability Reauirements (III.D.3.4. NUREG 0737. TMI .!
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'l Action Plan Reauirements) ~
This requirement mandated PECo to provide assurances' that during accidental _ releases of toxic or radioactive gases in or around the facility the operators would be protected, and could safely shutdown the reactor if necessar PECo submitted, via the Final Safety Analysis Report (FSAR), the results of their design - of the control room and its protective features to safeguard the operators against the release of toxic or radioactive gasses. The NRC issued the Safety Analysis Report (SAR)
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t which states the following: .
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The NRC staff has evaluated the control! room doses following a postulated , LOCA, in accordance with Standard Review Plan (SRP) 6.4, and finds the 4 i calculated whole body and thyroid doses to be within the guidelines of the Generali
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- Design Criteria (GDC). i
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The NRC staff has also evaluated the habitability of the control room with respect ~ ' to toxic gases, in accordance with SRP 6.4 and Regulatory Guides (RGs) 1.78 and - i 1.95, and concludes that the control room habitability systems provide adequate , protection against toxic gases, i
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Based upon the foregoing, the NRC staff finds that'the' applicant (PECo) has _ l
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' control room operators in accordance~with the requirements of GDC 19 and,
- therefore, compliance with NUREG-0737 Item III.D.3.4 is established. -
I , The inspector reviewed the following to insure that the systems outlined in the FSAR are l being operated in accordance with established procedures and are;being tested in - accordance with Technical Specifications. The surveillance tests reviewed were the latest l
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tests performe Ooerating Procedures ! S90.1.A ' Startup of the Control Enclosure Chilled Water System (CECWS)- 'l OS90.1. A(COL) Equipment Alignment for Startup of the CECWS-l ' f S90.3 & 4. A Refrigerant Transfer and Addition Procedures for CECWS S90. Chemical Addition to CECWE S90. Startup of CECWS in Manual S90. Routine Inspection of CECWS SE-2 - Actio'ns Taken in the Control Room in the Event of Toxic Gas-l -- Release . J , I r - ,.1, , --
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s . j I14 Surveillance Test Procedures ST-6-090-230-0 - CECWS Pump Valve and Flow Test ST-6-078-320-0 Control Enclosure HVAC Operability Test 1 RT-6-100-903-0 Routine Inspection of Control Room Emergency Fresh Air -l System .
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ST-2-078-604, 605 0 Toxic Gas Detection System-Control' Enclosure Air Intake ! Channel A and B Functional Tests (31 days)- 3
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ST-2-078-600, 601, Chlorine Detection System-Control Enclosure Air 606 and 607 ' Intake Chlorine Detector. Channele A, B,: C. and D j Functional Tests (31 days) _ . ._ ST-2-078-404, 405-0 Toxic Gas Detection System :- Control Enclosure Air Intake
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Channel A and B Calibration / Functional Test (18 months) ST-2-078-400, 401, Chlorine Detection System Control Enclosure Air < ;
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406 and 407-0 Intake Chlorine ' Detector L Channel A, B,' . C ' and D, Calibration / Functional Test'(4 months)' ST-2-026-607, 608-0 Radiation Monitoring - Main Control Room Normal Fresh Air Supply Radiation Monitors Channels A and C, B ands } ' D Functional Test (31 days) _ ST-2-026-429 0 Radiation Monitoring - Control. Room Direct Radiation . ; Monitoring Calibration / Functional Test (18 months).
ST-2-026-421, 422, Radiation Monitoring - Main Centrol Room Normal 433 and 424-0 Fresh Air Supply Radiation Monitor; Division I,' Channel:
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A, Division II,' Channel B, Division III, Channel C and' Division IV, Channel D Calibration Test (18 Months)- Based on the review of the above, the inspector concluded that the systems necessary to ;
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protect the control room habitability requirements were in place and in an operational condition. TMI Action Item III.D.3.4 is close ' ' Followuo of Previous Insoection Findings (Closed) Violation (50-352/90-15 01). This violation addressed the failure to follow procedures while transferring resins to the . waste sludge tank. The inspector reviewed 1 PECo's response to this violation, dated August 8,1990. The root cause was attributed to personnel error by a non-licensed operator and procedural compliance not sufficientl > L stressed by Operations Management. Corrective actions included counseling of the individual on the importance of procedural compliance,' emphasizing the event in the-operations training program, incorporating the importance' of procedural compliance in ,
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the requalification training program,'and changing the modification which was being installed in the resin transfer system to enhance resin transfers and prevent recurrenc ~ The inspector concluded that PECo's analysis and response to the event were thoroug This item is close :
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, 15 l l (Closed) Unresolved Items (50-352/90-04-01 and 50-352/90-04-02). These items L documented violations of NRC fire protection requirements.' The violations involved the' failure to provide adequate fire protection features for certain cables and equipment for: the Reactor Core Isolation Cooling (RCIC) system and Reactor Water Cleanup (RWCU) . 'l System _ as described in the Fire. Protection Evaluation Report (FPER). Upon . i l identification of the deficiencies PECo took prompt compensatory measures in the form j of fire watches in the affected area Nettary modifications are scheduled for I completion by the end of the current Unit I refueling outag , These violations were the subject of an Enforcement Conference held at the NRC Region j I office on February 23, 1990. Based upon the violations being licensee identified, prompt reporting to tb NRC, and the comprehensive corrective actions taken by PECo,L i the NRC Regional Administrator (after consultation with the Director of the Office of'
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Enforcement) decided to exercise enforcement discretion and.not issue a Notice of-Violation. This decision is documented in a letter from the NRC Region I to PECo dated March 28,1990. Based on these actions these items are close (Closed) Unresolved Item (50 352/87-23-01). This item addressed a concern that during 1
local leak rate testing of certain valves, the valve packing would not be pressurized and thus potential packing leakage would not be included in the test results. This. condition ; may exist due to the orientation of the valve packing relative to the valve seat and the t direction in which the test pressure is applie y PECo has reviewed this concern and identified various' isolation valves with~ this j
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configuration. Plant modification 5730 was implemented to alleviate these concerns. The modification used one of the following' methods to ensureLtesting of the associated packing: ,
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The valves were rotated 180 degrees to subject the packing to test pressur Additional block and test valves were added to permit testing of valves which could not be rotate Valves with packing leakoff ports were modified to permit individual testing o i l the valve packin Those valves which are normally below the level of water in'the' suppression pool - were reviewed and it was determined that they were not within the scope of.10 CFR 50 Appendix J (due to the' fact that any potential leakage path is sealed by
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water from the suppression pool).
Based upon the above actions this item is closed.-
' (Closed) Violation (50-352/88-02-06). This violation- was . written < when the L documentation for EQ package 194 (environmental qualification of AMP butt ' splices)-
could not be produced by PECo. The technical application of the AMP butt splices was ( ' acceptable, however, due to the Wyle test report and-other data reviewed at the time.
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16 -1 i Package 194 has since been revised to an auditable format and was reviewed by the ] inspector. Based on this review and the review of PECo's response to the violation the ' ) inspector concluded that the item is close j
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l (Closed) Unresolved Item (50-352/87 31-02).: This item pertains to smoke leakage from - . an exhaust flange due to lobe oil burning in the exhaust piping. This 'causes the fire alarm to sound when the diesel is started and has a' potential to start a fire. A plant - modification has been engineered to address this problem as' delineated in Inspection'-
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Report 50-352/90-06. Installation of this modification is scheduled to begin in the near future. In the' interim, PECo personnel have properly responded to every fire alarm-sounded when a diesel is started and there has never been a fire as 'a result of the leaking . , lube oil. The inspector had no further questions regarding resolution of this issue and-considers this item closed.-
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10.0 Exit Interview
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10.1 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 Acting Plant Manager, Mr. John W.; Spencer, on' September 14,1990. : No written inspection material was provided to licensee representatives during the inspection perio j 10.2 Additional NRC Insoections this Period -
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The following inspector exit interviews were attended during the report period: Date Subiegl Report .Insoector- [ 8/27 - 8/31 Emergency Planning 90-21/90 20 ; Amato ' ,
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9/10 - 9/18 Engineering - 90-22/90-21 McBrearty : Carasco
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LIMERICK GENERATING STATION ' UNIT 1
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PREPARATION FOR THE DISPOSITION . OF THE N2H NOZZLE INDICATION
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i DISPOSITION OF THE N2H NOZZLE:lNDICATION: 1 i i : i
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- - - BACKGROUND INFORMATION '
! - DISPOSITION ALTERNATIVES l , i - THE MS!P ANALYSIS' i' ! . L - OTHER RELEVANT INFORMATION !
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L - SCHEDULE FOR EXAMINATION-AND. DISPOSITIO .
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BAC'KGROUND J
- UT indication identified during the 2nd refuel outage 4
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- Located in a Rectroulation inlet nozzle to safe end weld -
- Dispositioned 'uso as is' with CA/S monitoring- g
- Latest CAV8 data indicates 0.024 finches of growth :j
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ALTERNATIVES i
- Olsposition Algorithm ; 'Use as is' with or without monitoring l - Apply the Mechanical-Stess improvement ProcessL(MSIP) - Perform a-weld overlay-- j
MSIP ANALYSIS t
- Generic Letter 88-01 limitations 1 - SMC O'Donnell to present their MSIP. analysis *
OTHER RELEVANI_lMEORMATION
- Identical. repeat of the UT examination - 1 - Graph of Indication Dimensions - MSIP to be implemented by SMC O'Donnell under 'contigency Purchase Order d - Weld Overlay'to be implemented by:GE underl -
i contingency Purchase Order q SCHEDULE
- Driven by Hydrolazing activity
- Examination is to be-performed on4 September 17th
- Ultimate l disposition to.be made.on September 20th
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N2H NOZ.ZLE TO SAFE-END WELD EXAMit'IATION SCHEDULE
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A'ITACHMENT 1 , a PECo Engineering Meeting ' N2H Nor21e Weld Indication August 29,1990 l Attendssa Philadelnhia Electric Comnany L. C. Benedict, NESD, Metallurgy S. J. Bobyock, LOS, Maintenance Engineering D. Groves, NESD, Mechanical Equipment Engineering R. Hess, NESD, Mechanical System Section K. Hudson, NESD, Piping Engineering K. M. Knalde, LGS, Maintenance Engineering R. Krich, NESD, Licensing ) M. J. McCormick, LGS, Plant Manager i D. B. Neff, LGS, Licensing i L. Purick, NES l
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D. L. Schmidt, LGS, Maintenance Engineering R. H. Zong, NESD, Metallurgy SMC O'Donnell (SMCO) E. Hampton, SMCO, Sr. Vice President i T. Damico, SMCO, Sr. Consultant :
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J. Porowski, SMCO, Vice President t Other Attendees D. Butrovick, GE/NSSS W. R. Norton, HSB I&l U.S. Nuclear Regulatory Commission I T. Kenny, Sr. Resident, Limerick i A l.ohmeier, Reactor Engineer, R1 l l v,: - - .- }}