IR 05000353/1988002

Insp Rept 50-353/88-02 on 880125-29.No Violations Noted. Major Areas Inspected:Preoperational Test Program Including Review of Test Procedures,Overall Program Review Requirements & Qa/Qc Interface

ML20151A822
Person / Time
Site:	Limerick
Issue date:	03/30/1988
From:	Eapen P, Vankessel H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151A815	List: IR 05000353/1988002 ML20151A811
References
50-353-88-02, 50-353-88-2, NUDOCS 8804070251
Download: ML20151A822 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /88-02 Docket N License N CPPR-107 Category B Licensee: Philadelphia Electric C Market Street Philadelphia, PA 19101 Facility Name: Limerick Unit 2 Nuclear Generating Station Inspection At: Limerick, Pennsylvania Inspection Conducted t Janugy_25-29, 1988 Inspector: b

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Henri F. vanKessel, Reactor Engineer date Approved by: es A6 . -

. P. K. Eapen, Chi p Special Test Section, Jho/75

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d6te B, OR Inspection Summary: Routine Unannounced Inspection on January 25-29, 1988 (Inspection Number 5073 53/88-02)

Areas Inspected: Preoperational Test Program including the review of preoperational test procedures, the review of the overall preoperational test program review requirements, and the review of activities in the QA/QC interface with the preoperational test program. Also witnessed a "blue tag" test and determined the status / schedule of the preoperational test progra Results: No violations were identified. Methods for Verifying test personnel proficiency in test procedures and revision of startup manual to clarify requirements for recorded communication after test interruption were identified as unresolved item Note: For acronyms not cefined refer to NUREG, 0544, "Handbook of Acronyms and Initialisms." 1 I

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8804070251 880331 PDR ADOCK 05000353 Q DCD

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Details 1.0 Persons Contacted Philadelphia Electric C J. M. Corcoran, QA/QC Manager M. Brewer, Assistant Chairman IRB S. Cohen, Nuclear Engineer

• D. A. DiPaolo, Startup QA Supervisor A. L. Klopp, Test Review Board Member

• B. T. Foote, QA-Engineer (Bechtel)

J. Jacyshyn, Field Engineer D. M. Kelsey, I&C and PM Coordinator

• G. Lauderback Jr, Startup QC Supervisor

• L. McCullough, Project Startup Engineer (Bechtel)

• K. W. Meck, QA Coordinator

• J. J. Milito, Superintendent Startup Support F. Krenke, Field Engineer G. Ludwig, QC Engineer

• J. C. Nagle, Test Review Board Chairman J. A. Hulton, Startup Coordinator

• T. Ullrich, Startup Manager

• F. M. Valentino, Construction Engineer R. D. Weingard, I&C Supervisor

• R. Wiegle, Superintendent Startup Operations U.S. Nuclear Regulatory Commission

• F. L. Fuhrmeister, Resident Inspector

• R. A. Gramm, Senior Resident Inspector

• Denotes those present during exit meeting held on Ja.nuary 29, 198 .0 Preoperational Test (POT) Program 2.1 Preoperationa, Test Program Revie The preoperational test program was reviewed, in part, against the requirements of the FSAR Chapter 14 and the Startup Admir.istrative manual, with PECO Startup Managemen Most of the questions on the POT program, as presented by the inspector, were answered satisfactoril There were, however, two

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questions which required further clarificatio l

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The first question concerned the methods to assure that personnel involved in the conduct of a test are knowledgeable of the test procedures. The Startup Administrative Manual needs to identify what these methods are. Startup management acknowledged that this question needs to be addressed. This item remains unresolved pending licensee actions to define methods to assure that personnel involved in preoperational test are knowledgeable of test procedures (Unresolved Item 50-353/88-02-01).

The second question concerned test interruptions and continuation of an interrupted tes The Startup Administrative Manual needs to clarify what is to be done in terms of recorded communication between the test engineer / test director and the Shift Supervisor of operation Startup management acknowledged this need to be clarifie This item remains unresolved ?ending licensee's revision of Startup Manual to clarify the requirements for recorded communications during an interrupted test (Unresolved Item 50-353/88-02).

No violations or deviations were identifie .2 Preoperational Test Procedure Review The preoperational test procedures as listed in Attachment A were reviewed for the following attributes:

Management review and approval

• Procecure format

• Clarity of stated objectives

• Prerequisites

• Environmental conditions

• Acceptance criteria and their sources

References

• Initial conditions

• Attainment of test objectives I I

• Test performance documentation and verification

• Degree of detail for test instructions

Restoration of system to normal af ter testing i

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• Identification of test personnel

• Evaluation of test data e Independent verification of critical steps or parameters

• Quality control and assurance involvement Findings No noncompliances were identified by the inspector within the scope of this inspectio .3 "Blue Tag" Testing The inspector witnessed a blue tag test on Panels 204201 and 20Y201 (Schematic Diagram E-184, rev. 4). This test was a control circuit verification test. The licensee representatives informed the inspector that Safety Related circuits will be tested using the same metho The inspector made the following observations:

(1) There were 2 temporary modification tsgs (pink) in panel 204201. The inspector verified that these tags were logged in the temporary modification log, as require (2) A voltmeter (PECo No. 32-2010) was used in the test. This instrument showed a calibration sticker with a calibration due date of November 6, 1988 1.e., a valid calibratio (3) While there was a generic test record available for this test, there were no formalized detailed test instructions availabl The test technician had made written detailed test instructions, (17 steps at different locations) for himsel These instructions, however, were not formally approved by anybody. Two changes were made to these instructions to maka it wor (4) A yellow lined schematic was produced as part of the test record to show that all contacts and relays in the circuit had been teste (5) The test was performed successfully after the two corrections (see 3 above) had been mad (6) A PECo QC inspector was witnessing the tes He was working with a detailed checklist for pre-energization tests of the pane He checked the tags present in the panel (204201) and the validity of the calibration of the test instrument (voltmeter). He also verified the various readings on voltag ._ - - .

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(7) A PECo QA inspector was witnessing the test. He did not work with a checklist but made notes on the same items as in (5) ,

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It was understood that circuit tests for safety related circuits would be conducted in the same manner i.e. without formalized  !

specific test instructions for each circuit. The inspector will >

further explore this item in a future inspection. The validity of 1 this approach is especially important considering that PECo plans to ,

skip such circuit testing in the preoperational tests if the data of the completed blue tag test are available and the test engineer does i not want to repeat these tests. The inspector understands that the  ;

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steps for these circuit tests will be included in the preoperational test procedure (with an asterisk) but will not be performed except '

as stated abov .4 Preoperational Test Program Implementation 2. . Review of Startup Personnel Qualifications and Trainin <

The inspector reviewed the qualification records of 12

Supervisory startup personnel against the requirements in 1 the Startup Administrative manual (SAM). The qualification

, record and the training records showed that all .

requirements of the SAM had been met for all personnel and  !

that these records were current. There was only one file missing for this supervisory group. This record was being i

updated for medical dat The inspector will review this I record in a future inspectio I 2. Test Review Board (TRB) Meeting

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The inspector attended a TRB meeting on preoperational tot procedure 2P93.3, "Main Turbine Supervisory System" and made the following observations:

(1) All of the members of the TRB necessary for the review of the procedure were present, i

(2) It was proposed to remove the reactor feedwater pumps l d

from the objectives (Objective #2). It was noted, j j however, that its removal from this procedure might '

lead to its inclusion in another procedure or the  !

creation of a new procedure.

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_ ____ .-_ _____________- ______ _ -____ _ _ -____________-_____- - _ - _ ____-_ ._-

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(3) It was noted that associated acceptance test data have to be available and are to be attached to the test result If these data are not available a test exception will be issued requiring TRB approva (4) A drawing revision status check will be made prior to the test as required by the Startup Manua (5) The proposed change in Scope of the POT procedure (2P93.3), as discussed under item (2) above, led the TRB to the conclusion to disapprove the procedure and to provide more time to resolve this questio It was concluded that the TRB functioned as required by the TRB manual and the Startup manua .0 QA/QC Interface Discussions were held with QA management on the involvement of QA and QC with the Startup program. The following observations were made:

(1) PECo QA gets involved with the components testing (blue tag testing). Hold points and check lists are used by the QC inspectors (see Section 2.3 above).

(2) QA will do witnessing of preoperational test: on a selective basis (approx. 20*;) . The selection covers approximately 80'4 ef the NRCs mandatory test (3) QA has drafted a check list to be used for pre-operational test witnessin A number of important SAM requirements are covered in this checklis (4) QA will review flushing, technical test, preoperational test, and some administrative procedures. QA will not review acceptance test procedures because these associated systems are not important to safet (5) Restoration of equipment in the "pink tag" (turned over to startup)

status would be done under a startup work order under Construction QC, Small jobs, however, would be done by PECo QC, (6) Startup QC is presently being re-organized into 2 groups. One group will be for administrative QC, the other group for "hands-on" Q (7) For blue tag testing there are generic checklist . . -

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(8) Startup QA presently has a total of 21 QA engineers, 10 in ,

Electrical / Civil and 11 in the mechanical discipline. Startup QC ,

has a total of 10 QC people including 3 in the administrative group and 7 inspectors in the inspection grou (9) PECo's Startup QC signs off on system restoration after blue tag test (10) QA will audit approximately 5% of the flushing activitie (11) Startup QA reviews turnover packages (as does Bechtel QA). '

No unacceptable conditions were observe !

4.0 Plant Tours  !

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The inspector made a tour of the plant including the Reactor building, l

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l Emergency Diesel Generator building, turbine building, and reactor l containment to observe the status of construction, work in progress, l

! housekeeping, testing activities and cleanlines !

No unacceptable conditions were note .0 Unresolved Items Unresolved items are matters about which more information is required in order to determine whether they are acceptable, an item of noncompliance,

) or a deviation. New unresolved items in this report are identified in paragraph ,

6.0 Exit Interview  !

At the conclusion of the site inspection, on January 29, 1988, an exit ;

interview was conducted with the licensee's senior site representatives (denoted in Section 1). The findings were identified and previous inspection items were discusse At no time during this inspection was written material provided to the licensee by the inspector. Based on the NRC Region I review of this report and discussions held with licensee representatives during this ,

inspection, it was determined that this report does not contain .

information subject to 10 CFR 2.790 restriction l l

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i Attachment A: Preoperational Test Procedures Reviewed Proc. N Description Rev. N Appr. Date TRB 2P kV Safeguard Power System 0 12-23-87 2P V Safeguard Load Centers 0 12-23-87 2P V Safeguard Motor Control 0 11-05-87 Centers 2P1 Service Water System 0 10-09-87 2P1 Reactor Enclosure Cooling Water 0 07-07-87 System 2P1 Turbine Enclosure Cooling Water 0 06-16-87 System 2P1 Instrument AC Power System 0 11-12-87 2P1 Instrument Air System 0 11-30-87 2P2 Primary Control Instrument Gas 0 11-11-87 l

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