IR 05000353/1989010
| ML20244B502 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/10/1989 |
| From: | Eapen P, Moy D, James Trapp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20244B500 | List: |
| References | |
| 50-353-89-10, NUDOCS 8904190236 | |
| Download: ML20244B502 (10) | |
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U.S. NUCLEAR REGULATORY ~ COMMISSION
REGION I
l Report No.
50-353/89-10 Docket No.
50-353 l
License No.
CPPR-107 Category B
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- Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 i
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Facility Name:
Limerick Generating Station, Unit No. 2 Inspection _At:
Limerick, Pennsylvania Inspection Conducted-February 6 - 16, 1989
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Inspectors:
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James M. Tr<>pp, actor Ehgineer
'date i STPS, EB, DRS
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Daniel T.61oy, ea tor Engineer date /
STPS, EB, DRS Approved by:
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'O N Dr. P K. Eapen, Chidf, Special Test Programs date Section,.EB, DRS Inspection Summary:
Routine Unannounced Inspection on February 6-16, 1989 (Inspection Report No. 50-353/89-10)
Areas Inspected: The preoperational test program implementat. ion, preoperational test procedurer, preoperational test results, and the QA/QC involvement in the
., preoperational test program. The preoperational tests for standby liquid control system, control rod drive hydraulic system, and the reactor protection system were wftnessed.
Results: No violations were identified.
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l 890419023687jh53 PDR ADOCK O PDC
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DETAILS 1.0 Persons Contacted 1.1 Philadelphia Electric Company
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A. Beard, Startup Engineer l
J. M. Corcoran, Startup Supt., Support
G. C. Kelly, LSQA Engineer M. Kemp, Startup Engineer F. Ginfrida, Lead PECo Field Engineer
G. Lauderback Jr., Startup QC Supv.
- K. Meck, QA Asst. Supt.
W. L. McCullough, Project Startup Eng.
- J. C. Nagle, Test Review Board Chairman
B. Simmons, Startup Engineer W. White, Startup Engineer H. R. Wiegle, Startup Supt, OPS.
1.2 US Nuclear Regulatory Commission
R. L. Fuhrmeister, Resident Inspector
Y. G. Hsii, Acting Chief, STP Section
- . Denotes those present during exit meeting held on February 16, 1989 2.0 Preoperational Test Program
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2.1 Preoperational Test Procedure Review (70332, 70307, 70305, 70356)
The test procedures listed in Attachment A were reviewed.
The procedures were examined for:
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
j Test performance documentation and verification
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Degree of detail for test instructions
Restoration of system to normal after testing
Identification of test personnel
Evaluation of test data
Independent verification of critical steps or parameters
Quality control and assurance involvement
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-3-The inspector performed a detailed technical review of preoperational procedure 2P-59.2 Rev.' 0,'"Preoperational Primary Reactor Containment Integrated Leakage ~ Rate Test Procedure." The review assured that commitments contained.in the following reference documents were
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incorporated into.the test procedures:
10 CFR Part-50 Appendix J a
Limerick FSAR
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- ANSI /ANS 56.8-1981 " Containment System Leakage test
requirements"
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BN-TOP-1, Rev. 1, November-1, 1982,." Testing Criteria for Integrated
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a Leakage Rate Testing of Primary Containment Structures for Nuclear Power Plants" Preoperational'. Procedure 2P.59.2, Rev. O, Step 6.3(23) requires the ILRT instrumentation be functionally checked after final installation.
This step states that the functional check shall be performed per
' ANSI /ANS. 56.8-1981.
However, it does not provide instructions or acceptance criteria listed in ANSI /ANS-56.8.
In addition, the pro-cedure does not provide data sheets or other means'of documenting the results of.this calibration.
Upon identification of this concern, the licensee representatives stated this matter would be reviewed for resolution. This is an unresolved item (89-10-01).
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.The inspector did not have any comments on the other procedures reviewed.
No noncompliance were identified by the. inspector within the scope of this inspection.
2.2 TestWitnessing(70432,70317,-70456)
The inspector witnessed selected steps of the procedures listed in Attachment A and the following were verified:
0verall crew performance
Use of latest revised end approved procedure by test personnel
Designation of~one person in charge of conducting the tests
Availability of sufficient test personnel to perform the tests
Coverage of test prerequisites
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Use of acceptance criteria to evaluate test results
Supporting systems are in service
i In-service status of calibrated special test equipment required
by the test procedure l
Adherence to the test requirements of the test procedure during
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the tests Timely and correct action by test personnel during the tests
Data collection for final analysis by test personnel
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-4-i The inspector witnessed the Individual Rod Scram Test (Preoperational Procedure 2P-55.1 Rev. 0), for selected controi rods.
The inspector independently verified the scram time and the buffer time for six randomly selected control rods. The buffer times for the six control rods verified met the acceptance criteria provided by the procedure.
All six control rods independently verified had scram times below l
the 1.5 second minimum acceptance criterion. A test engineer stated
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that several other control rod scram times were also below the 1.5 i
second minimum acceptance criterion. A test exception had been written and the licensee stated that a Field Deviation Disposition Request would be written to General Electric requesting a resolution following the conclusion of this test.
The coordination among the personnel conducting this test was good.
Each member of the test team had adequate knowledge of the tasks being performed.
The test i
was implemented in accordance with the Procedure and Administrative
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Directives on test implementation.
The inspector witnessed selected sections of Preoperational Test for l
the (Procedure 2P-53.1) " Standby Liquid Control System." The inspector
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observed two isolated instances where this procedure was not followed:
(a) Step 6.4.4.3(13) requires, in part, the electrical leads to the Squib valve be disconnected at the valve.
The test engineer began removing the electrical leads to the Squib valve at the terminal box. The inspector discussed the intent of this step j
with the test Engineer, after which, the leads were replaced at the terminal box and removed from the valve.
(b) Step 6.4.4.3(36) has a note which states, in part, that " audible indication is not a reliable method to determine Relief Valve Set Point." However, the test was first conducted using audible indication of Relief Valve Setpoint. After this method failed to yield acceptable results, the test was repeated using the guidance supplied in the note.
In spite of the above, the inspector found the test engineer knowledge-able on the contents of the procedure ana the system being tested.
i All other steps of this procedure witnessed by the inspector were strictly followed.
The inspector witnessed selected steps of the Reactor Protection
System Preoperational test 2P-58.1.
During testing of the Rosenount
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Drywell pressure and Reactor Vessel level transmitters, three of the eight transmitters tested failed. The failure caused changes in the
calibration of the transmitter which prevented the performance of the
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preoperational test for the failed transmitters. -The test engineer stated that failure analysis would be performed for the transmitters to determine the root cause of the high failure rate.
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-5-The inspector reviewed all test exceptions and Test Change Notices documented during the tests selected for the inspection.
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instances, the test exceptions and test change notices were disposi-tioned properly by the responsible startup engineer.
No violations were identified by the inspector.
2.3 Test Result Evaluation (70400)
The test procedures listed in Attachment A were reviewed to verify that the testing was accomplished in accordance with regulatory requirements and licensee commitments.
The inspector also verified that uniform criteria were being applied for the evaluation of completed preoperational tests to assure their technical and administrative adequacy.
The inspector made the following observation while reviewing the results of the preoperational test 2P-79.2G, Rev. O, " South Stack Effluent Radiation Monitoring System." The Preoperational Test Endorsement Record (Appendix K of AD8.3P Rev. 9), Section 6, " Review and Approval of Open Test Exceptions," was not complete. However, Step 11 of Appendix A to Administrative Directive (AD) 6.6, Rev. 3,
"Startup/ Component Release to PECo Operations" has been initialled off to indicate that the documentation package is complete and ready to be turned over to Nuclear Records Management System (NRMS). The licensee indicated that they would revise Step 11 of Appendix A to AD 6.6 to identify exceptions when all of the documents are not ready for transfer at the time of release to operations. The rewritten AD 6.6 was presented to.the inspector at the exit meeting.
In addition, the licensee stated at the exit meeting, that the startup group will retain the responsibility for tracking open test exceptions on systems turned over to operations until the test exceptions are closed or at the time of licensing. The licensee also stated, that the startup group plans to maintain a log of open test exceptions for systems turned over to operations. The inspector found these actions
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to be acceptable.
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3.0. t.icensee Actions on Previously Identified Items I
(Closed) Unresolved Items 353/88-13-01, 353/88-13-02:
Cleanliness class I
definition of fuel oil systems and lube oil syttem; and cleaning procedures
for on-skid piping and components.
References 1.
Field Change Request ME-1218-M, " Cleanliness Control of Piping and Equipment," for revision of design document 8031-P-303, approved on 6-16-88.
2.
Field Change Request ME-1254-M, " Cleanliness Control of Piping ana Equipment," for revision of design document 8031-P-303, approved on 7-13-88.
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Field Change Request ME-1279-M, " Cleanness Cont'rol of Piping and Equipment," for revision of design document 8031-P-303, approved on 7-28-88.
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" Specification for Cleanliness Control of Piping and Equipment,"
8031-P-303, Rev. 13, approved 12-28-87.
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Inspection Report 50-353/88-22, Section 3.
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Limerick FSAR Section 9.5.4.2
- Discussion During inspection 50-353/88-13 the NRC inspector identified five concerns regarding the Emergency Diesel Generator (EDG) lube and fuel oil clean-liness' classifications. All but one of these concerns were addressed by the. licensee and found acceptable by the inspector, as documented in inspection report 50-353/88-22. The remaining concern was the cleanliness classification of the fuel oil transfer system upstream of the duplex
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. filters (F575). The licensee classified this section of piping cleanliness
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class "D."
'FSAR Section 9.5.4.2, " Diesel Oil Storage Tanks Corrosion Protection,"
.provides the design basis for the prevention of corrosion products or debris from entering the EDG fuel injectors.
The FSAR states in part that, "Should particulate accumulate in the fuel oil system, the transfer
. system is designed to prevent their entry into the diesel generator fuel oil injectors." Based on this information, the inspector has determined that cleanliness class "D" is adequate for the EDG transfer system upstream of the duplex filters. This item is closed.
4.0'-QA/QC Interface The QA audit and surveillance reports listed in Attachment B and QA/QC involvement with the preoparational test program were reviewed. The following reports reviewed had unsatisfactory findings by QA.
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Licensee Audit 2S-143 was performed to ensure that Unit 2/ Unit 1 differences b
are satisfactorily documented and evaluated.
The licensee issued three findings to document noncompliance with AD6,11 requirements.
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The reviewing coordinator did not identify traicing recommendations g
on two difference forms.
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The project engineer did not identify if the difference would remain
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cpen at fuel load on two differences.
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Four difference forms were not signed off by the reviewing i
coordinator, as evidence of concurrence with the project engineer's resolution.
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-7 The inspector found the. recommended' correctives action,- to properly complete the above difference forms acceptable and had no questions regarding this audit report.
Licensee Audit 2S-146 was performed to evaluate the performance of Preoperational Test 2P-50.1, " Reactor Core Isolation Cooling System (RCIC)." This audit report had one unsatisfactory finding.
Operability
- testing of MOV HV-492 F031 per procedure required the valve to open..
.During testing, the valve failed to open. The startup engineer failed to recognize this as a test failure / exception.. The corrective actions taken-for this finding were to write a test exception, write a Startup Work Order (SW0), repair the valve, and perform additional training' for the test engineers. The inspector found the corrective actions adequate.
Licensee Audit report 2S-148 evaluated the startup preventative mainte-nance (PM) program. The audit found six preventative maintenance activities that were not performed or deferred in accordance with Administrative Directive (AD) 6.10 Rev 3.
The inspector reviewed Startup PMs for the Diesel Generators and' the Standby Liquid Control System. The inspector found the PMs were being handled in accordance with AD 6.10 and had no further questions concerning this subject.
5.0: Plant Tours ~(70302)-
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The inspector made several tours of the plant including the Control Room, Reactor Enclosure, Drywell, Turbine Enclosure, and Emergency Diesel Generator Enclosure, to observe the status of construction, work in progress, housekeeping, testing activities and cleanliness.
The inspector reviewed three temporary modifications to ensure compliance with Administrative Directive (AD) 6.8, " Temporary Modification Control."
The inspector made the following observations.
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A temporary modification tag was required, but was not located on the spectacle flange positioned in the auxiliary steam supply line to the RCIC turbine.
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The lemporary Modification log entry was complete but tags were still in place for the Emergency Diesel Gsnerator. jacket water power pill modification.
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Blank flanges located on the RHR pump suction strainers were
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removed.
The Temp-orary Modification tags for the strainer blank flanges were still in place.
The Test Engineer stated he was waiting for completion of paper work indicating the blank flanges were removed, prior to clearing the temporary modification.
The inspector identified the above tagging concerns to the licersee's representative. The licensee agreed to review this : natter for generic implications.
No unacceptable conditions were identified.
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6.' 0 Exit Interview
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' At the conclusion of the. site inspection.on February 16, 1989 an exit l
interview was conducted with the' licensee's senior site representatives
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.(denoted in Section 1).. 'The findings.were identified and previous inspection items were discussed.
At no time during this inspection was written material provided to the
, 1 licensee by the inspector. ' Based on the NRC Region I review of this
report and discussions held with licensee representatives during this
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inspection,.it was determined that this report does not contain
'information' subject to'10 CFR 2.790 restrictions.
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' Attachment'A-
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Preoperational Test Procedure Review '(PR),-Test Wit' essing.
n (TW),-and Test Results Review (TRE).
Proc. No.
- Description'
Act. Code-Rev. No.
2P5.1 Safeguard'440V. Load Centers-
.TRE
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2P34'.1-Reactor Enclosure HVAC PR
2P53.1-
.. Standby Liquid Control-PR,- TW.
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'2P55.1 <
Control: Rod Drive Hyd-aulic Syst.
PR, TW
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'2P58 1 Reactor: Protection System PR, TW
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2P59.2
--ILRT Procedure-PR
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2P79.1A
. Area. Radiation Monitoring Syst..-
TRE,
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2P79.2G South Stack Effluent Mon. Syst.
TRE
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i Attachment B QA Audit Reports Reviewed Report No.
Subject Unsct Findings 2S-111 2P-25.1 Primary Cont. Instr. Gas NONE 2S-136 2P-61.1 RWCU NONE 2S-143 Unit 2/1 design diff.
YES 2S-144 2P-59.1 Cont. Isol. & NSSSS NONE 2S-145 Rework activities NONE 2S-146 2P-50.1 RCIC YES 2S-148 PM-EDG YES 2S-150 2P-100.4 Standby D.G. Load Test NONE 2S-152 2P-52.1 HPCI NONE 25-153 2P-2.2 125/250 VDC Safeguards Power NONE
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