IR 05000353/1988022

Insp Rept 50-353/88-22 on 880912-23.No Violations Noted. Major Areas Inspected:Preoperational Test Program,Including Review of Implementation Requirements,Preoperational Test Procedures & Integrated Sys Flush Test

ML20195B522
Person / Time
Site:	Limerick
Issue date:	10/18/1988
From:	Eapen P, Moy D, James Trapp, Van Kessel H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20195B517	List: IR 05000353/1988022 ML20195B512
References
50-353-88-22, NUDOCS 8811020062
Download: ML20195B522 (13)

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /88-22 Docket N Licerse N CPPR-107 Category B Licensee: Philadelphia Electric Company 2301 Market Street kh11adelphia, Pennsylvania 1910f Facility Name: Limerick Nuclear Generating Station, Unit 2 Inspection At: Limerick, Pennsylvania Inspection Conducted: September 12-23, 1988

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I Inspectors: N 4 'Iv % h .ff A l o - l'7 - F F Henri f.. van Kessel, Reactor Engineer date h .h /?[[L James I Jo -t 9M date

        .T,ragp,RectorEngineer
        ['" 'V.m lC )[C     I D - n-9 9 (,, Daniel T. Hoy, Reactor Engineer     date Approved by:    . IP!/f 7 p. K. Espen, Chief, Special Test Programs
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Section, EB, DRS Inspection Summary: Routine Unannourmed Inspection or. September 12-23, 1983 (Inspection Report No. 50-353/83'22) t Areas Inspected: Preoperational test program, including the review of the preoperation W test program implementation requirements, preoperational test $ procedures; activities in the QA/QC interface with preoperational test program; preoperational tests for Emergency Diesel Generators A, C, and D and for Recirculation Pumps A and B; and the Integrated System Flush Test, procedure 2F6 Results: No violations were identified, es11020062 691026 FDR ADOCK 0500g'{3

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1. Persons Contacted Philadelphia Electric Company (PECO)

* D. Bradley, QA En6.ver (Bechtel)

M. Brittingham, Tesi, Director

"J. M. Corcoran, Mansger Qual,'ty Assurance R. Chester, QA Engineer E. Co urove, Shift Supervisor
*J. A. Dannert, QC Staff (Bechtel)
*T. Dey, QA Engineer
* A. 01 Paolo QA Superintencent, Unit 2 M. Franchuk, QA Engineer M. Gearhart, Test Director
* Hatton, Quality Engineer (Bechtel)

J. Higgins, Startup Engineer

* Lauderback, Startup QC Supervisor
" L. McCullough, Project Startup Engineer (Be:htel)

K. W. Meck, Assistant Superintendent QA J. Mitman, Shift Startup Engineer T. S. Panetta, Startup Engineer

*R. L. Payne, QA Engineer
*R. H. Slaughter, Project Quali+.y Engineer (Bechtel)

5. S. lickers, Startup Engineer B. Stanley, Shift Superintendent

* T. Ullrich, Startup Manager, Unit 2 W. White, Startup Engineer
*H. R. Wiegle, Startup Superintendent Operations U.S. Nuclear Regulatory Commission
* L. Fuhrmeister, Resident Inspector
*0enotes tho:e present during exit meeting held on September 23, 1983 Preoperational Test Program 2.1 Preoperational Test Procedure Review The following test procedures were reviewed:
 * 2F62.1, "Cleannass Verification Procedure, Startup System N A, Reactor Vessel," Rev. '
 * 2F64.1, "Preoperational Test Reactor Recirculation System,"

Startup Subsystems 64A and 64 . - - -

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The above test precedures were reviewed for the following attributes:

* Management review and approval
* Procedure format
* Clarity of stated objectives
* Prerequisites
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Environmental conditions

* Acceptance criteria and their sources
* References
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Initial conditions

* Attainment of test objectives
* Test performance documentation and verification
* Degree of detail for test instructions
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Restoration of system to normal after testing

* Identification of test personnel
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Evaluation of test data e Independent verification of critical steps or paramet.t rs

* Quality control and assurance involvement The following observations were made with respect to flush procedure 2F62.1: The procedure was concise and had clearly stated objectives, prerequisites, initial conditions and acceptance criteri . The instructions did not always accomplish the procedure objectives. Nearly all of the instruction sections required temporary modifications prior to execution. Most of the changes were caused by system changes and water inventory problem . The temporary procedure modifications reviewed were adequately controlled and approve . The procedure referred to valves by number only and did not supply the function of the valve. Without knowing the function, a typographical error on the valve number has the potential to cause the wrong valve to be operate Observation No. 4 above was discussed with startup managemen It was agreed that all valve numbers in the remaining flush procedures will be checked against the applicable systen drawings to make sure that there are no typographical error The review of preoperational test procedure 2P64.1 for the RCS did not reveal any unacceptable conditions, t

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2.2 Test Witnessing The inspe: tors witnessed the following tests:

* 2P24.1, "Preoperational Test Proced1re, Standby Diesel Generators System, Startup Subsystem 24A," Rev. * 2P64.1, "Preoperatonal Test Procedure, Reactor Recirculation System, Startup Subsystems 64A and 64C," Rev. * 2F62.1, "Cleanness Verification Procedure, Startup System N A, Reactor Vessel," Rev. Test witr.assing by the inspector included observations of the following attributes:
* Overall crew performance a l'se of latest revised and approved procedure by test personnel
* Designation of one person in charge of conducting the tests
* Availability of sufficient test personnel tu 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 procrJure
* Adherence to the test requirements of the test procedure during the tests
* Timely and correct action by test personnel during the performance of the tests
* Data collection for final analysis by test personnel For procedure 2P24.1, the inspector witnessed the unloaded and loaded run on Standby Diesel Generator "D" (SDG). This unit had experienced high vibration levels during a previous run. An extra balancing weight was placed on the fly wheel near the coupling of the diesel-generato The vibration level was reduced by approximately 2 mils, but was still high during the unloaded run. The vibration level was acceptable during runs at load. Additional efforts were also made to bring the vibration down to more normal level Bearing No. 10 of SDG-D was damaged during the loaded ru Examina-tion of the damaged surface of the lower aluminum bearing half suggests the intrusion of foreign material, perhaps a burr from the new bearing itsel The damaged bearing will be replaced shortl ,
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The inspector witnessed the logic functional tests of SDG-C and independently verified the results of steps 16.4.1.6(9) and 16.4.2.1(4) for Filter Dynamic Valve 92-2406C. Bubbles were observed to rise in the lube oil in the crankcase. The test instruments, used for the logic functional tests, had valid calibratfor.s i.e., PEC0 Number 01-0438 (Digital Clamp) with due date 9-13-89 and PECO Number 57-0620 (Fluke Multimeter) with due date 11-17-8 The inspector witnessed air starts on SDG"A" and SDG"C". The acceptance criteria for recovery time for frequency and voltage (<10 sec.) and the 5 starts on the air receiver witaout excessive pressure loss, were met in all cases observed. Test exception 34 was issued for the errcr in the procedure (2P24.1) with regard to the valve line up on the air system (valve 92-230A). Test exception 35 was issued to record the slow frequency response problem of the visicorder. The rpm signal was used to replace the frequency signa The inspector witnessed the flow tests of Recirculation Pump "B" using preoperational test 2P64.1. The scoop tube positioner was unstable. Test exception TE-39 was issued to addrcss this concer Pump speed was restricted to 36.5% to avoid cavitation during the tes The inspector witnessed flushes, using procedure 2F62.1, for the following flow paths:

* The main recirculation flow path; RPV to hotwell and hctwell back to RP * Main recirculation flow path and RHR system operating in the shutdown cooling mod * Main recirculation flow path with Core Spray Pumps injecting into the PR * Main recirculation flow path und RHR system injecting into the vessel via the LPCI penetration The inspector conducted field walks to verify that the initial conditions were established in accordance with the procedur Initial Condition Step 4.1.7 required u.terous olind flanges to be installed on the RCIC Steam Supply / Exhaust lines and a hose be con-nected between the Steam Supply and Exhaust. The inspector verified that these steps were completed and the temporary equipment used was adequate for the applications. The inspector found the initial conditions steps were completed in accordance with the procedure and all the temporary modifications were logged indicating that they were

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for use during this procedure. The inspector conducted similar inspections of the temporary modification made to HPCI (initial condition step 4.1.6) and the SRV's (initial condition step 4.1.3).

The purpose of the integrated f?ush is to clean vessels and piping following constructio System:. are flushed by pumping Condensate Storage Tank (CST) or Suppressien Pool Water through the piping and vessels. The main recirculation flow path was from the Hotwell via the condensate pumps, through the normal feedwater paths to the Reactor Pressure Vessel (RPV) and back to the hotwell via the Main Steam lines. During this procedure the RPV Head was removed and the steam dryer and moisture separator were removed from the RP The flush was continued until water samples taken from the flow ' stream were f und to meet pre-established acceptance criteria. The samples were first passed through sample cloths to check for large particles of debri If the sample cloths were found acceptable a sample was sent to chemistry for analysis. The chemist measured the following parameters: ,

*  Ph
*  Fluoride
*  Chloride
*  Conductivity
*  Silica
*  Turbidity The inspector found the overall execution of the procedure to be adequate. Equipment was operated by a licensed Reactor Operator (R.O.)

under the direction of the test enginee The communications established between the test engineer, R.O. and field operators were good. The test engineer kept the master copy of the test procedure up-to-date. Quality Assurance also was active in covering the execu-tion of this procedur Other systems flushed using this procedure are: RHR System Core Spray System Recirculation System Steam Supply / Exhaust to RCIC and HPCI i The inspector examined the sample cloths from the FWCU System Flush Test. The personnel were experienced and knowledgeable in conducting this type of testing. The inspector reviewed the chemistry test results of the RHR and Core Spray Systems. The samples were acceptable as they met the acceptance criteria specified in the procedur . .

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7 Licensee Actions on Previously Icentified Items (0 pen) Unresolved Items 353/88-13-01 and 02: Cleanliness class definition of fuel oil systems and lube oil system; and cleaning procedures for on-skid piping and component References Field Change Request ME-1218-M, "Cleanliness Control of Piping and Equipment," for revision of design document 8031-P-303, approved on 6-16-8 . Field Change Request ME-1254-M, "Cleanliness Control of Piping and Equipment," for revision of design document 8031-P-303, approved on 7-13-8 . Field Change Request ME-1279-M, "Cleanness Control of Piping and Equipment," for revision of design document 8031-P-303, approved on 7-28-88.

' "Specification for Cleanliness Control of Piping and Equipment," 8031-P-303, Rev. 13, approved 12-28-8 Discussion

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The concerns with respect to the cleaning methods, acceptance i criteria for cleanliness of systems and components and the cleaning procedures for the lube oil and fuel oil systems of the Emergancy Diesel Generators (EDGs), as discussed in inspection report 50-353/88-13, have been addressed by the license Reference (1) was issued to add Secticn 1.5 to Spec. P303, (ref. 4).

This step included the lube oil systems in the specification for the first tim It also adds the classification of these oil systems in

Table II as class "C." This classification is not adequate to maintain i the required cleanliness for the fuel oil piping and the fuel injection j pumps downstream of the 5 micron fuel oil filcers.

Reference (2) was issued to add Section 8 to Spec.. P-303 (ref. 4).

In this section the inspection criteria for the ILbe oil systems, as identified in Section 1.5 (see above), are identified to be those of paragraph 1.3.2 of P-303 which specifies that there si.311 be "no particles of sand, metal, or slag regardless of size." This is a very tight specification and it will not allow the presence of any '. lapping compound containing silicates (for abrasion) of any particle size no matter how small.

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Section 8 also states that "procedures shall be established for performing work on flushed lube oil systems for maintenance of cleanliness levels". It should be noted that new section 8 does not address fuel oil systems directly. This tie-in, however, is made via note 20. Section 8, however, applies only to the fuel oil piping and equipment downstream of the 5 micron fuel oil filters of the EDG Classification D for fuel oil piping is considered to be too low a classification for all of the EDG fuel oil piping. It is also inconsistent with the acceptance criteria of P-303, paragraph 1.3.2 which are applied to the fuel oil piping downstream of the 5 micron filter via note 20. On the basis of note 20, the classifica-tion of this fuel oil piping needs to be changed to Class The fuel oil piping upstream of the 5 micron filter then would automatically classify as Class B by its own definition in P-303 (ref. 4).

In summary, the following observations are made: The cleanliness criteria of paragraph 1.3.2 of Specifications P-303, as applied to EDG lube oil and to EDG fuel oil (via note 20) are acceptable . The classification of the EDG lube oil and fuel oil systems, both on-skid and off-skid installation, are not consistent with the strict cleanliness criteria of paragraph 1.3.1 of P-30 Class C, for instance, has its own acceptance criteria which are well below those of paragraph 1. Procedures are not in place to assure adherence to the ac-ceptance criteria of paragraph 1.3.2 of P-303 upon intrusion into the EDG lube oil or fuel oil system It should be noted here that the reconditioning of EDG bearings requires the temporary exposure of the lube oil system. There is no pro-cedure to meet the high cleanliness standards inherent in paragraph 1.3.2 of P-30 Lapping compounds containing silicates (sand), therefore, m.st be completely removed after bearing / journal repair because "sand particles are not to be present regardless of size."

(Closed) Unresolved Item 353/88-08-02: "Revision number and date on exhibit firms for turnover packages."

During NRC inspection 353/88-08, the inspector identified that the forms (ExhiLits) provided in Bechtel procedure CP-f-1, and used to control 3 tuo over packages, did not contain revision numbers. This had led to the use of two different revisions of Exhibit 4 in turnover packages 2-05A-1F and 2-15A-1 , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ *.

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In response to this finding, the licensee has performed a complete review of all exhibits / forms shown in the jobsite Construction Procedure As a result of this review, construction has revised (as necessary) the exhibits / forms used to document quality information in the field to include the procedure exhibit and revision number. These exhibits / forms will be controlled via a matrix maintained by the Quality Engineering Department and contain the following informatio * Discipline

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Procedure Number

   * Title
   * Exhibit Number
   * Revision
   * Remarks Based on the above review, the inspector considers this unresolved item to be close . QA/QC Interface The QA Audits and Surveillances as listed in Attachment B were reviewed to ascertain the continued QA/QC involvement with the preoperational test progra Finding Report 25-169 (from Report 25-115) discussed deficiencies in ident ifying and controlling temporary system modifications, installed for testing purpose Temporary test equipment installed in the Reactor Enclosure Cooling Water (RECW) system for test 2FB1 (para. 4.1.2) was not identified with T-Mod tags. The corrective action was t- provide the T-mod tags for all of the test equipment used in test procedure 2 FB 14.1. To prevent recurrence of this problem, training bulletin 88-G-068 was issued to all startup engineers to reemphasize the requirements of administrative procedure AD 6.8 for temporary modifications. This finding by startup QA is in the same area exposed by the inspector in Section 5 belo Finding Report 25-171 (from report 25-120) observed that a number of test instruments, as used in Technical Test Procedure 2F49.1 for RHR System Cleanness Verification, had expired calibration due date The instruments were recalibrated or exchanged for calibrated instruments. A recommendation was made to retrain personnel for the procedural / program requirements. The inspector found this corrective action acceptable.

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10 Temporary Modifications (70302) A number of temporary modification items were selected from l the Temoorary Modification Log (TML) as shown in Attachment Conditions, as recorded in the TML were checked against the actual

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cwittions as found in the fiel Items 37-001 and 87-007 were consistent with the TML. TML No. 88-008, indicer.ed that the two steam inlet blind flanges were tagged for the Integrated Rectrc. Flush, 2F62.1, Step 4.1.2.3. However, this TML tag .<as missing. In the case of TML No. 88-001, the two hoses at valves 48-2F0 25B and 48-2F0 15 were found disconnected (quick disconnects) and at a small distance from the valves. The tags for TML 88-001 were found on the hoses. While this condition, as found, would theoretically be a restored condition, the disconnected hoses make this restoration incomplete. The corrective actions for the above two items will be followed under Unresolved Item 353/88-22-0 . Plant Tours (70302) The inspector made several tours of the plant including the Control , Room, Reactor Enclosure, Drywell, Turbine Enclosure, and Emergency i Diesel Generator Enclosures, to observe the status of construction, l work in progress, housekeeping, testing activities and cleanlines In the Control Room, the inspector verified a report that the feedwater suction and discharge valve controls are located on panel i 20C-651 while the feedwater pump controls are on panel 20C-603, l approximately 8 feet away from the controls on panel 20C-651. This l 1s seen as a Human Engineering Deficiency (HED). The licensee is in the process of performing an analysis to determine this HED's impact on safety. The completion of this analysis will be followed under Unresolved Item 50-353/88-22-0 It was also noted that the mimics of the bench boards were rather minimal. The inspectors will followup on this item in a future inspection. Apart from the above items, no unacceptable conditions were note . Unresolve11tems Unresolved items are matters about which more information is required in order to determine whether they are acceptable, items of noncompliance, or deviations. New unresolved items in this report are identified in Sections 5 and J

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11 Exit Interview At the conclusion of the site inspection, on September 23, 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 '

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ATTACHMENT A Selected Items from Temporary Modification log T Mod Log N System Description 87-001 Core Spray Blank Flange in lieu of Strainer, showed restored condition in lo RCIC Pump Suction Strainer, spool piece w/o basket installed; not restore RCIC Two steam inlet blind flanges and steam exhaust drain blind flange installe SLC For flush of 2F53.1, had attached drain hoses for SWO-253-007 in area 17 at elevation 283' in Reactor Enclosur / J

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ATTACHMENT B Review of QA Audit / Surveillance Reports Report No. Description Rep. Date 2S-120 Technical Testing of RHR System 2P-49A 9-14-88 25-119 Technical Testing of Core Spray System 2P-51A 8-29-88 25-118 Startup Control of Flush procedures 9-2-88 25-116 Preop. Testing Fuel Pool Cooling & Cleanup S-29-88 System 2P-35A 25-115 Flow Balance Rx Enclosure Cooling Water 8-29-88 25-121 Performance of Core Spray Syste Flush 9-12-88 l

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