IR 05000353/1988018

Insp Rept 50-353/88-18 on 880627-0807.No Violations Noted. Major Areas Inspected:Work Activities,Procedures & Records Re Tech Spec Review,Engineering,Plant Water Spills & Assurance of Quality & Plant Insp Tours

ML20151Y867
Person / Time
Site:	Limerick
Issue date:	08/17/1988
From:	Linville J, Williams J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151Y863	List: IR 05000353/1988018 ML20151Y860
References
50-353-88-18, NUDOCS 8808290068
Download: ML20151Y867 (12)

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U. 3. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 88-18 Docket No. 50-353 License No. CPPR-107 Category A/B Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Faci.lity Name: Limerick Generating Station, Unit 2 Inspection Conducted: June 27, 1988 to August 7, 1988 Inspectors: R. A. Gramm, Senior Resident Inspector, Unit 2 R. L. Fuhrmeister, Resident Inspector, Unit 2 Reviewed by: _/ w . 8 /1!BT gns, Project Engineer Ofte'

R c r r6dects Section 2A Approved by: / .

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7 17 g Ja Liny le, Chief /0ath R cto P oj cts Section 2A In;pection Summary: Report for Inspection Conducted June 27. 1988 to August 7, 1988 (Report No. 50-353/88-18)

Areas Inspected: Routine inspection by the resident inspector of work acti-vities, procedures, and records relative to Technical Specification review, preoperational test procedure review, engineering, plant water spills and as-surance of quality. The inspectors reviewed licensee action on previously identified items and performed plant inspection tours. The inspection involved 146 hours0.00169 days <br />0.0406 hours <br />2.414021e-4 weeks <br />5.5553e-5 months <br /> by the inspector Results: No violations were identified.

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TABLE OF CONTENTS PAGE 1.0 Summary . ............................ 1 2.0 Plant Inspection Tours. . . . . . . . . . . . . . . . . . . . . . 1 3.0 Licensee Action on Previously Identified Items. . . . . . . . . . 4 4.0 Licensee Action on Bulletins and Circulars. . . . . . . . . . . . 6 5.0 Three Mile Island Action Plan Items . . . . . . . . . . . . . . . 7 6.0 Technical Specification Review. . . . . . . . . . . . . . . . . . 7 7.0 Preoperational Test Procedure Review. . . . . . . . . . . . . . . 8 8.0 Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 9.0 P l a n t Wa t e r S p i l l s . . . . . . . . . . . . . . . . . . . . . . . 10 10.0 Assurance of Quality. . . . . . . . . . . . . . . . . . . . . . 10 11.0 Meetings with Licensee. . . . . . . . . . . . . . . . . . . . . 11 i

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DETAILS 1.0 Summary Twelve NRC open items were reviewed and 11 were closed (Section 3, 4 ana 5). The PECo management tracking system for NRC correspondence will be examined due to the untimely response to Bulletin 86-02. Several equip-ment tests were witnessed and numerous licensee raports were reviewed (section2). The proposed Unit 2 Technical Specifications were reviewed (section 6). Four preoperational test procedures were reviewed for technical adequacy and one unresolved item was initiated regarding the selection of the suppression pool water level for core spray pur.p opera-tion (section 7). The Bechtel engineering improvement plan actions were reviewed (section 8) and the licensee investigation into threa water spills was reviewed (section 9),

2.0 Plant Inspection Tours (371302, 335301, 251053, 237055, 335301, 235060)

The inspector observed in progress work activities, completed work, and plant status in several areas during inspection tours. Work was examined for defects and compliance with regulatory and licensee requirement Particular note was taken of the presence of quality control inspectors and quality control evidence such as inspection records, material iden-tification, nonconforming material identification, housekeeping and equipment preservation. The inspector interviewed craft supervision, craft and quality control personnel in the work areas. Observations are noted below:

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The inspector witnessed a portion of the Safeguard Fill Pump 2AP256 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> run. This pump run was performed tv satisfy licensee com-mitments in response to NRC Bulletin 83-05 regarding Hayward Tyler pump The inspector observed further application of component labels. The l highly visible labels are color coded to depict Unit 2 equipmen Piping and HVAC duct are marked with: system identity, unit iden-tity, flow direction, P&ID and duct pressure ratin The cleanliness condition of battery cells 49, 50 and 51 of the division B battery room were noted to have a slight amount of par-ticulate contamination on the top of the battery cell The licensee was informed and the cells were cleane A small leak was noted at valve 57-2008B where a collection bucket had overflowed. The licensee was informed of the open valve and the area was promptly cleaned u _- - _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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The inspector accompanied Bechtel, PECo and General Electric per- I

sonnel during a seismic qualification walkdown for instrument rack  ;

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20C041. The questionable seismic clearances were noted for further -

investigation. The inspector reviewed several walkdown documents and-  :

interviewed the engineering personnel involved with effor l

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The inspector observed several test runs for standby diesel engines I a A and The bearing run-in tests were performed in accordance with i vendor instructions. The tests were performed by field engineering with support from operations personnel, vibration monitoring tech-nicians and a vendor representative, j

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The inspector reviewed the Limerick 2 Readiness Verification Program  !

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(RVP) verification matrix item assignments. The verification items *

l were derived from: the PECo Readiness Program Assessment, NRC in- i

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spection modules, the Peach Bottom restart plan, results of NRC team  :

inspections at other nuclear facilities, Limerick Unit 1 Licensee Event Reports, NRC Limerick 2 inspection findings, NRC NUREG reports  !

and INPO operating experience reports. PECo organizations have been  !

i assigned areas of responsibility to perform verification checks to  :

assure the RVP elements have been properly addressed. The imple- -

mentation of the RVP will be reviewed in future NRC inspection ;

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The inspector reviewed a startup report that indicated limitorque l 1 operators had grease added to the operators that contained small i amounts of sand. The questionable grease had been detected by ,

Bechtel QC in the limitorque rework shop. The grease was traced to '

a single lot of Exxon Nebula EPO grease. The inspector reviewed i Nonconformance Report 13632 that identified safety related valves

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! where the grease had been utilized. Exxon evaluated the suspect  !

j grease and determined that it would not harm the operators. PEco  ;

test results for the grease indicated that it contained sand. Test 6 i

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results from a third laboratory are outstanding. The affected operators will be cleaned to remove the grease which contains the i centaminan l t

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PECo contracted General Electric to provide a review of power as- l j cension test problems at four recent Near Term Operating License  ;

(NTOL) plants. The problems were identified in GE startup daily  ;

i reports and Licensee Event Reports. The problems were correlated with affected system and corrective action if known. The inspector t i reviewed the list and found the overall conclusions similar to NRC  !

! NUREG-12/5, Volume 1. The report will be of some usefulness for j

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startup engineers to proactively address potential problem areas.

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The inspector reviewed the PECo QA 1987 annual review for the l

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Limerick 2 quality program. The PECo report identified areas of l j weakness related to engineering activities. Other project areas were  !

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found generally well controlled which was consistent with the NRC SALP repor The annual report further identified areas to focus the conduct of future PECo audit activitie No violations were identifie .0 Licensee Action on Previously Identified Items (92700. 92701, 92702) (Closed) Construction Deficiency Report (83-00-05): Diesel generator fuel oil storage tank interior coatin The inspector reviewed the following documents related to the defective epoxy phenolic interior tank coating:

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PECo QA Audit 2M-564

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Bechtel QCFM-7807

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Bechtel Quality Action Request QAR-F-433

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Limerick Licensing Document Change Notice FS-1255

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Bechtel Nonconformance Report 11543 The interior surfaces of the tank were blast cleaned with abrasive material. After cleaning and inspection was performed, the bottom one foot of th(tank was epoxy coated. The uncoated surfaces were protected with in application of oil to prevent corrosion. Quality control inspections and quality assurance audits were performed to assure the work was properly performed. This item is close (Closed) Constru: tion Deficiency Report (83-00-12): Defective sili-con controlled rectifiers (SCRs) in load center breakers supplied by Brown Boveri. The inspector reviewed the following documents re-lating to the defective circuit breakers:

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PECo Notification pursuant to 10 CFR 50.55(e)

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Brown Boveri letter to PEco dated April 16, 1934

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Startup Nonconformance Report S-61-E

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Startup Nonconformance Report S-62-E

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PECo Field Engineering Speed Letter to PECo QA dated July 23, 1988

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Testing and Labs Division Procedure for Acceptance Testing of ITE K-line Static Circuit Breakers (TL-11-04014, Rev. 3)

SCRs in the solid state trip units of some ITE (Brown Boveri) K-line circuit breakers exhibited excessive leakage currents. This could have caused unanticipated and undesirable tripping of these circuit breakers. All suspect units were rettrned to the vendor for testing and reconditioning as necessary. In addition, PECo procedures call for testing of any of the spare circuit areakers or trip units before they are placed in service. This item it close _ - _ - _ _ - _ - _ _ - _ -

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5 (Closed) Construction Deficiency Report (84-00-08): Defective HMA relays. The inspector reviewed the following documents relating to the defective relays:

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GE Notification pursuant to 10 CFR 21 dated December _ 16, 1982

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GE Field Disposition Instruction (FDI) TRQF, Rev. 0, 1

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GE FDI LRAR, Rev. 0

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GE FDI LRAS, Rev. 1

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GE FDI LRBF, Rev. 0

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GE FOI LRBG, Rev. O, 1, 2

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Bechtel Work Package ECR-20C618-001

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Bechtel Work Package ECR-200641-001 Certain HMA relays produced in early 1974 exhibited insufficient clearance on the armature tail piece. Thirteen relays of this type were used in GE supplied panels for safety related systems. These relays were inspected and those found with insufficient clearance were corrected in accordance with instructions proviued by GE Power Systems Management Business Department. This item is close (Closed) Violation (84-08-01): Storage of equipment. The inspector reviewed the following documents:

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PECo QA Finding Report N-397

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BCI Interoffice Memorandum, Control No. F245688

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BCI Interoffice Memorandum, Control No. F246689

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Field Inspection Report M79-M123-P100

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NCR No. 11546

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Routine Test, RT-4-020-900-1, Inspection of diesel fuel oil storage tank pit, Rev. O The items of non-compliance noted were corrected and degraded equip -

ment was refurbished as necessary. Inspection frequencies were in-created and a periodic check for water accumulation in the valve pits was instituted. This item is closed, (Closed) Unresolved (88-01-01): Temporary space heaters for standby

, diesel generators. The inspector reviewed PECo QA Finding Reports 2N-616 and 2N-591. The external heaters were energized and verified by firewatch personnel that perform around-the-clock checks of the diesel areas. The heaters were prematurely removed from the Bechtel firewatch log and were put back on the firewatch log until the diesel generators were turned over to the startup organization. This item is close (Closed) Violation (88-10-01): Instrument rack as-built welded con-figuration. The inspector reviewed the following documents:

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PECo Finding Report 2N-613

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General Electric (GE) Field Deviation Disposition Request HH2-8694 The licensee investigated the instrument rack weld deviations on the Unit 2 racks. The effect of the undersized fillet welds and missing stiffness plate welds was evaluated by GE. The rack dynamic test results were found to provide sufficient margin to accommodate'the missing and undersized weldments and the racks were found acceptabl The rack fabrication was performed by a GE subcontractor and GE has no anticipated orders for new racks. This item is closed.

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4.0 Licensee Action or, Bulletins and Circulars (92703)

The inspector reviewed licensee records related to the Bulletins and

! Circulars identified below to verify that: the Bulletin or Circular was i

received and reviewed for applicability; a written response was provided

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if required; and the corrective action taken was adequate. The following Bulletins and Circulars were reviewed:

I [ Closed) Bulletin (76-03): Relay malfunctions-GE type STD relay The licensee determined that the subject relays are not used in Class 1E applications. The items are identified on the PECo Alert List to

preclude future use. This item is closed.

> (Closed) Circular (79-21): Prevention of unplanned releases of q radioactivit The inspector reviewed the following document FSAR section 11.2-9

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PECo S procedures index

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Procedure 561.1.A, "Normal Setup for Reactor Enclosure and Tur-bine Enclosure Liquid Radwaste Collection"

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PECo Administrative Procedure A-97, "Isolation Tag Control Pro-cedure"

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Bechtel Specifications G-40 and P-314

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Bechtel Letter BLP-32882 The inspector was informed that liquid radwaste system valve lineup checklists are reviewed by the Plant Operating Review Committee and the QA audits are periodically performed to assure procedural com-pliance, Bechtel engineering design review responsibility included:

verification that overflow lines are directed to the appropriate collection points, verification of st'ficient leak collection capa-city for radioactive system pumps and verification of floor drains and curbs for radioactive system valve The inspector noted that provisions had been made by the licensee to isolate contaminated Unit 1 systems from Unit 2 construction area This item is close _ _ _ - _ _ _ _ _ _ _ _

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7 {, Closed) , Circular (81-07): Control of radioactively contaminated material. The inspector reviewed the following documents:

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HP-810, "Radioactive Material Control" HP-210. "Radiation Survey Techniques" HP-211 "Contamination Survey Techniques"

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TL-12-00437, "Calibration of Eberline RM-20 GM Count Rate Meter" The procedures address releases of material from the radiologically controlled area, direct survey techniques, instrument calibration, smear sample analysis and personnel qualification. This item is close (0 pen) Bulletin (86-02): Static "0" ring differential pressure switches. The licensee reviewed the plant design and determined that none of the suspect pressure switches are installed in the plan This item has been added to the PECo Alert List to preclude future use. The inspector noted that the PECo response to the NRC was ap-proximately one year late. Pending review of PECo management tracking systems to ensure timely response to NRC correspondence, this item remains ope (Closed) Bulletin (88-03): Inadequate latch equipment in HFA type latching relays manufactured by GE. The licensee determined that these relays are not utilized in Class 1E electrical systems. This component has been added to the PECo Alert List. This item is close .0 Three Mile Island Action Plan Items (325401B)

(Closed) I.C.8: Pilot monitoring of selected emergency procedures for near term operating license applicants. The inspector reviewed FSAR section 1.13 and SER section 13.5.2.3. The pilot mcaitoring program was used on an interim basis until the Boiling Water Reactor Owners Group (BWROG) emergency procedures had been approved. The Limerick Trip pro-cedures were developed from the BWROG emergency procedures. This item is close .0 Technical Specification Review (371301)

On June 3, 1988, the licensee submitted the proposed Unit 2 Technical Specifications to the NRC. The changes from current Unit 1 Technical Specifications were clearly highlighted. The inspector reviewed the proposed Technical Specifications, the standard Technical Specifications for Boiling Water Reactors (NUREG 0123) and portions of the Susquehanna Unit 2 Technical Specifications. The changes were found generally minor in nature. The basis for several changes will be discussed at a future meeting between the NRC and the licensee. The basis for not revising the Emergency Service Water action statements will also be discussed. No violations were identifie _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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7.0 Preoperational Test Procedure Review (370304, 370336, 370305)

The inspector reviewed the following preoperational test procedures for technical content, conformance with the FSAR test abstracts (Table 14.2-4)

and consistency with the startup administrative manual requirements:

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2P52.1, "High Pressure Coolant Injection (HPCI) System". Additional documents reviewed include: FSAR sections 6.3 and 7.3.1.1.1.1; Piping and Instrument Diagrams (P& ids) M-52 sheets 3 and 4, M-55 sheet 2, M-56 sheet 2 and M-41 sheet 4; GE HPCI elementary diagrams; GE preoperational test specification 22A2271AY, purchase specifica-tions 21A9203 and 21A9243BS, design specification 22A6237 and design specification data sheet 22A6237AA. The inspector verified valve closure times, valve logic testing, HPCI automatic and manual in-itiation logic testing and HPCI turbine trip signal verificatio The inspector questioned an indicating lamp designation and was in-formed that an FDDR had been previously issued to correct the GE elementary diagra P58.1, "Reactor Protection System (NSSS)". Additional documents reviewed include: SER section 7.2; FSAR section 7.2; figures 7.2-1 and 7.2-2 and tables 7.2-1 and 7.2-2; single line diagrams E-32 and E-34; P& ids M-46 and M-47; electrical schematic diagrams E-129 and E-620; GE reactor protection system elementary diagrams and GE pre-operational test specification 22A2271AY. The inspector verified:

testing for RPS actuation one out-of-two twice logic; scram initi-ation from scram discharge volume high level; scram initiation from closure of more than two main steam isolation valves; scram initi-ation from fast closure of main turbine control valves; scram in-itiation from low reactor water level; control rod scram insertion times; and testing for fail safe function on loss of electrical powe The inspector questioned a typographical error in acceptance criteria (8) where "more" was substituted for "main". Test Change Notice 1 was issued to correct the acceptance criteria wordin P51.1, "Core Spray System". Additional documents reviewed include:

FSAR sections 6.3.2.2.3 and 7.3.1.1.1.3 and tables 6.3-1 and 6.3-2; GE preoperational test specification 22A2271AY, design specification 22A3787 and design specification data sheet 22A3787AB; P&ID M-52; electrical schematic diagrams E-350 and E-622 and GE core spray elementary diagram The inspector verified: valve logic testing;

valve closure times; core spray pump circuit breaker logic testing;

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core spray full flow verified within 27 seconds of initiation signal; system alarm testing; manual and automatic initiation testing. The inspector questioned the selection of 203 feet 11 inches for the suppression pool level during the pump tests to assure absence of vortex formation. Startup Field Report (SFR) 251A-023 was issued to request engineering review to determine the proper pool level since

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the FSAR stated that lowest level that would occur up to 30 days after a LOCA should be used for the test. This item is unresolved ;

(88-18-01). j

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2P-49.1 "Residual Hoat Removal System". Additional documents re- .

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viewed include: FSAR Sections 5.4.7, 6.3.2.2.4, 7.3.1.1.1.4, 7.4.1.4.4, 7.4.2.3.1; P&lD M-51, sheets 5, 6, 7 and 8; GE RHR elementary dia-grams; GE preoperational test program specification 22A2271AY; l various pump and valve control circuit schematic drawings. The in-spector verified proper valve closure times, valve logic testing, '

automatic initiation logic testing, pump starting interlocks and valve opening interlocks. The inspector noted only minor typo-graphical errors which will have no impact on test performance or result ,

No violations were identifie .0 Engineering (37055. 35060)  ;

t The licensee has developed an engineering improvement plant that includes i Bechtel and Gencral Electric engineering organizations. The primary focus  !

of the plan is to address concerns that were documented within the last  !

NRC Systematic Assessment of t.icensee Performance (SALP) for Limerick Unit t 2 (Report Number 50-353/87-99). Various elements of the improvement  ;

program have been implemented. The inspector reviewed the following  !

documents regarding the improvement plan:  :

i Document Description i Recommendation Matrix Describes implementation status for Chief Engineer reviews,

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Verticle Design Review of Project Change Notices (PCNs) 20.141 f Reviews regarding elimination of arbitrary and inter- ;

mediate pipe breaks; PCN 20,173 regarding local test taps; and PCN 5111N regarding replacement of Paul Monroe hydraulic actuator with Limitorque l operators for two reactor enclosure air recir- :

culation system damper [

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Bechtel Interoffice Evaluated previous problem areas with Unit 1 pur- '

Memorandum (IOM) chase orders with respect to implemented correc-tive action for Unit j i

Buchtel Letter Described the Bechtel and GE design interface j BLP-44084 agreemen Bechtel Letter Described the FSAR nonconformance survey results !

BLP-4401 where an item was added to the Design Closure plan,

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10 Bechtel IOM Defined the use of the EDPI 4.25.3 tracking control form to correlate the licensing document subject with the issued design document chang The licensee continues to expend significant resources to correct problem areas and to enhance the conduct of engineering activities. No violations were ider.tifie .0 plant Water Spills (371302)

The inspector attended a Plant Operations Review Committee (PORC) meeting regarding three incidents where water spills had occurred due to Unit 2 test activitie Due to leaking filter demineralizer outlet valves the condensate backwash receiving tank overflowed during the condensate system fine flush. The leaks were isolated and the spill was cleaned up. The leaking valves are scheduled for replacement with an upgraded model. No permanent equipment was damage Improper operation of a vacuum and air relief valve contributed to a spill during the service water flow balance. During transfer from the C to B pump, a low flow condition occurred and the valve did not seat. When the flow increased, the valve remained open and a spill resulted. Several Motor Control Centers (MCCs) were wetted down. The MCCs were deenergized, cleaned up and testing satisfactorily. Engineering was requested to re-view the relief valve discharge path and several pipe fittings were re-placed on the valves. The valve will be disassembled to identify any other causes for failure to seat and operating procedures will be written to address the proper method to accomplish the pump transfe During a circulating water pump run, the winter bypass valve was throttled to raise the system back pressure. The increase system head caused two circulating water pump discharge valves to leak. One pump manway was open and a spill resulted. The discharge valves were manually closed and the leak was eliminated. No equipment was damaged. The tagging personnel were reminced to manually verify that motor operated valves are closed prior to hanging blocking tag The PORC was observed to fully review the circumstances of the spills for impact on Unit 1 operations. The corrective actions implemented by the Unit 2 staff appeared appropriate. No violations were identifie .0 Assurance of Quality The plant labeling program provides highly visible color coded labels that will assist plant personnel with the operation of Unit 2 equipment (sec-tion 2).

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The Readiness Verification Program should provide a controlled methodology to assure plant readiness for NRC licensing (section 2).

Management tracking controls were found lacking as a required licensee response to an NRC Bulletin was received one year late (section 4).

The proposed Unit 2 Technical Specifications were reviewed and further discussions will transpire between the NRC and PECo relative to the Emergency Service Water Action statements. Unit I apparently was allowed relatively longer Limiting Condition for Operations (LCOs) based upon the fact that the Unit 2 pumps were energized and available to support Unit 1 exclusively. With the pumps in a permanent configuration to support dual unit operations, it seems necessary to readjust the LCO time limits ac-cordingly (section 6):

The quality of the preoperational test proced ses is apparent as only minor questions were identified during the NRC review (section 7).

In depth investigations and Unit I reviews were performed on three in-stances where water spills had occurred during Unit 2 test activitic To mitigate the potentia? for future spills valve lineups need to be per-formed in a manner to assure proper valve position which apparently was not done for the circulating water pump discharge valve (section 9).

11.0 Meetings with Licen,ee (237038)

The NRC resident inspector diset.ssed the issues and findings in this re-port with members of the licensee's staff on a weekly basis, and at an exit meeting held on August 5, 1988. Based on discussions held with licensee representatives on August 5, 1988, it was determined that tht:

report does not contain information subject to 10 CFR 2.790 restrictions.