IR 05000353/1988017

Insp Rept 50-353/88-17 on 880725-29.No Violations Noted. Major Areas Inspected:Preoperational Test Program,Including Review of Implementation Requirements,Procedures & Test Witnessing of Emergency Diesel Generator a

ML20154Q864
Person / Time
Site:	Limerick
Issue date:	09/08/1988
From:	Drysdale P, Eapen P, Van Kessel H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20154Q862	List: IR 05000353/1988017 ML20154Q859
References
50-353-88-17, NUDOCS 8810040089
Download: ML20154Q864 (11)

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I E U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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Report N /88-17 Docket N License No. CPPR-107 Category B Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Facility Name: Limerick Nuclear Generating Station, Unit 2 Inspection At: Limerick, Pennsylvania r

I Inspection Conducted: July 25-29, 1988 Inspectors: A b _

k~I-Henri F. van essel, Reactor Engineer date

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Peter Dr saale, Aeactor Engineer date i

Approved by: K.E&

Dr. P. K. Eapen, Chief, Special Test 9NPr

'date I Programs Section, EB, DRS i

Inspection Summary: Routine Unannounced Inspection on July 25-29, 1988 Linspection No. 50-353/88-17)

4 Areas Inspected: Preoperational test program, including the review of the I

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l preoperational test program implementation requirements, preoperational test

procedures, activities in the QA/QC interface with the preoperational test

program, preoperational test results, and the test witnessing of preoperational

tests for the Emergency Diesel Generator A.

I Inspection Results:

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! One unresolved item was identified dealing with a discrepancy found in preoperational test procedure 2P50.1 for the RCIC system.

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OETAILS 1.0 Persons Contacted 1,1 Philadelphia Electric Company (PECO)

R. Albin, QA Engineer J. Corcoran, Manager Quality

• 0. Cook, Construction Engineer

• D. A. DiPaolo, Superintendent Unit 2 QA

• G. C. Kelly, QA Engineer (Bechtel) -

S. G. Koneckny, QA Engineer (Bechtel)

• G. Lauderback Jr. Startup QC Supervisor J. Luccarella, Construction Engineer

• H. Lilligh, QA Manager (Bechtel)

• W. L. McCullough, Project Startup Enginee:- (Bechtel)

• K. W. Meck, Assistant Superintendent QA

• J. J. Milito, Startup Suparintendent Unit 2

• R. L. Payne, QA Engineer

• J. R. Pidgeon, QA Engineer W. T. Ullrich, Startup Manager

• R. Wiegle, Startup Superintendent Operations U.S. Nuclear Regulatory Commission R. A. Gramm, Senior Resident Inspector

• L. Fuhrmeister, Resident Inspector

• Denotes those present at exit meetin .0 Preoperational Test Program 2.1 Preoperational Test Procedure Review (70311; 70341; 70357 & 70360)

The preoperational test procedures as listed in Attachment A were reviewed for the following attributes:

• Management review and approval

• Procedure format

• Clarity of stated objectives

• Prerequisites

• Environmental conditions

• Acceptance criteria and their sources

• References

• Initial conditions

• Attainment of test objectives

• Test performance documentation and verification

• Degree of detail for tejt instructions a Restoration of system to normal after testing

• Identification of test personnel

Evaluation of test data

• Independent verification of critica* steps or paramoters

• Quality control and assurance involvement

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It was noted in the review of test procedure 2P50.1; page 2-18, Acceptance Criterion (47), that "The RCIC turbine trip throttle valve can be reset remotely af ter an electrical trip (FSAR Section 5.4.6.2.4.1(b))." How-ever, the quoted FSAR section only states one condition which is required for the RCIC system to be available in a standby mode for automatic opera-tion, i.e., valve HV-50-212 is ope Step 6.4.22.4.1(1)(c) of the pro-cedure accomplishes verification of the required valve position prior to the trip test, whereas, Step 6.4.22.4.2(1) resets valve HV-50-212 after the turbine trip test. Therefore, Acceptance Criterion (47) should refer

, to FSAR Section 5.4.6.2.4.1(n) which resets the throttle valve after the

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trip test.

PECo Startup Engineering has agreed to change the test procedure in ac-j cordance with the observations of the inspector as noted above. A TCN

will be prepared for this change prior to conducting the test. This item will be tracked under Unresolved Item 50-353/88-17-01.

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It was noted in procedure 2P56.1, Section 4.2, paragraph (14) that "Spe-cific test steps are not included (in the procedure) for the installation and removal of test equipment including the returning to service of system

, instruments as -- ." The inspector verified that there will be steps in

the procedure to install and remove test devices but the procedure will not provide details on how this is done. This is the responsibility of Testing and Labs (T&L).

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It was observed also that the option for performing the logic functional

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testing prior to the related preoperational test st?ll exists (asterisk items). The inspector learned that the choice is made by the Startup Project Engineer. The startup engineer is required to issue a letter to document his decision in each case.

l The inspector checked on the independent verification of critical steps in the procedures since there are no provisions shown in the approved pro-

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cedures reviewed. Hold points for such independent verification are assigned by Startup QC/QA after approval of the procedure and prior to approval to perform the test, in accordance with AP 8.3P paragraph (5.2b7)

. of the Startup Manual.

. Apart from Unresolved Item 353/88-17-01, no unacceptable conditions were l identified by the inspector within the scope of this inspectio .2 Test Witnessing (70441)

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The inspector witnessed tests on Emergency Diesel Generator A leading into the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> load test which is performed in accordance with the test instructions referenced below.

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Test witnessing by the inspector included observations of:

• Overall crew performance

• Use of latest revised and approved procedure by test personnel

Designation of one person in charge of conducting the test

• Availability of sufficient test personnel to perform the tests

• Coverage of test prerequisites

• Use of acceptance criteria to evaluate test results

• Verification that plant supporting systems are in service

• In-service status of calibrated special test equipment required by the test procedure

• Adherence to the test requirements of the test procedure during the tests

• Timely and correct action by test personnel during performance of the tests

• Data collection for final analysis by test personnel The inspector independently verified readings of system parameters during the test The first run of the diesel was aborted because the crankcase vacuum was too high (in excess of 3 inches of water). The orifice controlling this parameter was replaced and a second run was mad The crankcase vacuum decreased, however, the turbocharger vacuum was too high (in excess of 12 inches of water). Again the run was aborted. After removal of the vent screens, the test (3hr load test) was completed successfull It was noted during the second start of the diesel, that the speed controller had not been returned to the intended low idle speed settin The operator tripped the diesel to prevent it from exceeding the idle speed. There is no safety significance attached to this operation, as the requirement for low idle speed is established to protect the engine during initial run No unacceptable conditions were observed by the inspector during the tests.

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References ,

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(1) Startup Work Order (SWO) 2.24A-053, run-in procedure for D/G 2.24A, !

dated July 7,1988 l

r (2) Memorandum from G. A. Hunger, Nuclear Engineering - Engineering l Division (PECO), to G. M. Leitch, "Fairbanks Morse Mode! 38 T08-1/8 :

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Diesel Engine Pre-start Inspection and Replacements," dated March 28, 1988  :

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(3) A+.tachment A to SWO 2.24A-053, with engine parameters and loaded run data sheets. Shows recommended values against actual value :

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2.3 Test Result Evaluation (70329)

Scope The test procedures listed in Attachment B were reviewed to verify that adequate testing was accomplished to satisfy regulato y requirements and licensee commitments. Review was performed to also ascertain that uniform criteria were being applied to the evaluation of completed preoperational tests to assure technical and administrative adequac Discussion The test results were reviewed for:

• Test changes

• Test exceptions

Test deficiencies

• Acceptance criteria

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Performance verification

• Recording of conduct of test

+ QC inspection records

• System restoration to normal

• Independent verification of critical steps or parameters

• Identification of test personnel

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Verification that the test results have been approved

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It was noted in the review of procedure 2P6.1 that Test Change Notice (TCN) No. 1 identified several drawings which were several revisions behind. The test engineer is responsible for reviewing the design changes associated with these revisions for their impact on the validity of the test procedur This requirem:nt is discussed in more detail under Sectior. No unacceptable conditions were observed within the scope of +.his inspectio .0 Licensee Action an Previously Identified Items (70302)

(Closed) Un*esolved Items 353/8S-13-03 and 353/8S-11-07, "Procedure for Reviewing Document Changes".

References (1) PECO's QA Finding Report 2N-577, issuad to F. R. Solis of PECO Testing and Labs (T&L), dated 7-15-87 (2) Memorandum QAFCM L2-4356, "NRC Finding FR-2N-577", dated November 30, 1987 (3) Memorandum f rom F. R. Solis, PECO's Testing and Laborator ies Division to J. M. Corcoran, "Response to Finding FR-2N-577 and QA FOM L2-4356, dated February 25, 1988 (4) Implementing procedure TL-11-50014 "Control of the Calibration of Plant In<trumentation and Equipment" Rev. No.3, in draft for (5) Memorandum OA FCM L2-4644, "Finding 2N577." dated April 18, 198 Discussion Finding Report 2N577 (ref.1) documented the need for a formal T&L procedure for reviewing document changes for their effect on completed wor Corrective action has been taken on this finding by T&L (ref 3)

in the form of a revision to procedure TL-11-50014. This revision was issued prior to the end of the inspectio The inspecter also concurs with the action taken thereby closing Unresolved Item 50-353/83-13-0 Since Unresolved Item 50-353/87-11-07 deals with the same issue, it is also considered to be close <v -

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4.0 QA/QC Interface (53501)

The QA audits and surveillances listed in Attachment C were reviewed to ascertain continuing QA/QC involvement with the preoperational test progra Audit 25-88, on SFRs, SCRs, and SCNs, identified that SFRs are not being processed, logged, and approved as required by Startup Administrative Procedure AD 6.3, Rev. Specifically, Finding Report 25-146 identified:

• Line out changes were not initialed and dated a SFRs were signed but not dated a SFRs were approved but did not have all of the required informatio Corrective action on this finding has not been completed to dat The corrective action for Audit 25-96, related to the Startup Preventive Maintenance (PM) Program, states:

(1) "The reviews of "draft" system PM requirements were not being completed prior to system turnover to startup (FR-25-149)

(2) Reports identifying overdue system FMs were not issued as required ( FR-25-163 ) . The corrective action taken to prevent recurrence of the above was to notify all startup group supervisors that the Startup Superintendent of Operations nor the Project Startup Engineer will accept a system for turnover unless the input for the PM Data Base has been sent tu the Startup FM Coordinator."

The inspector inquired whether this corrective action will be incorporated in such administrative procedures as AD6.1, "System / Component Turnover to PECo." The Licensee intends to incorporate these corrective actions in a future revision of startup administrative pro;edure .0 Independent Effort The startup administrative procedure: were reviewed to determ.ine how design and drawing changes are incorporated in applicable test procedure The requirerents for the review of design / drawing changes, as referred to above, can be found in the Startup Administrative procedure AD 3.3F (pa .7b; 5.la.1; 5.3C.0, 5.3C1; 5.3C2;5.7).

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From a review of Startup Administrative Procedure AD 8.3P, it is clear that control of design drawing changes, in relation to the POT procedures, is adequate if enforce For the preoperational test results reviewed during this inspection, the inspector verified that the requirenents, except fer paragraph 5.3.C.1, were adequately implemente .0 Plant Tours and Diesel Generator Enclosures The inspector made tours of the plant including the Reactor Enclosure and Turbine Enclosure to observe the status of construction, work in progress, housekeeping, testing activities and cleanlines No unacceptable conditions were note .0 Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable; are items of noncompliance; or are deviations. One unresolved item in this report is identified in Section .0 Ex1t Interview

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At the conclusion of the site inspection on July 29, 1933, an exit interview was conducted with the licensee's senior site representatives (denoted in Section 1). The 'indings 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 :

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Attachment A Preoperational Test Procedures Reviewed Proc. N Description Rev. No Appr. Date TRB

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2P2 Ercargency Standby Power 0 06-13-88 2P3 Fuel Pool Cooling and Cleanup 0 05-19-8B 2P3 Cond. and Refuel Water Transfer 0 05-10-88 2P5 Reactor Core Isolation Cooling 0 06-27-88

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2P56.1A Reactor Manual Control 0 06-09-88 2P57.1B U.11nterruptible AC Power 0 02-23-88 2P10 Standby Diesel Generator 0 06-03-88 Loading

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F Attachment B Preoperational fest Results Review Proc. No. Description Rev. No A J pr. Date TRB (Test Results)

2P57.1B Unintarruptible AC Power 0 06-28-88 2P6,1 Safeguards 440V Motor 0 07-07-88 Control Centers 2P Safcguards 440V Load Centers 0 07-07-88-Startup Subsystem SA

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Attachment C Review of Audit / Surveillance Reports Report N Description Prep._Date 25-084 Startup Document Control 05-16-88 25-088 Startup Field Reports (SFRs), Startup 06-06-88 Change Requests (SCRs), Startua Change Notice (SCNs)25-095 Blue Tag Testing 07-08-88 25-096 Startup Preventive Maintenance Program 06-d7-88 25-097 Startup Work Order (SWO) Program 06-16-88 25101 Startup QC Program 06-03-88 25102 Startup Procurement of Technical Services 07-15-88

25-103 System Turnover Walkdowns 07-18-88 25-105 Blue Tag Testing of System 2-49A 07-05-88 25-108 Startup Recceds Control 07-21-88 i

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