IR 05000353/1989013
| ML20245G607 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/19/1989 |
| From: | Bonnett F, Eapen P, David Silk, James Trapp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20245G592 | List: |
| References | |
| 50-353-89-13, NUDOCS 8905030193 | |
| Download: ML20245G607 (9) | |
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U.S. NUCLEAD. REGULATORY COMMISSION
REGION I
Report No.
50-353/89-13 Docket No.
50-353 License No.
CPPR-107 Priority Category B Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:
Limerick Nuclear Generating Station,- Unit 2 Inspection At:
Limerick Pennsylvania Inspection Conducted:
February 27 - March 16, 1989 Inspectors:
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games ' 'rapp, Reactor Engineer
~date ll Y - 11 - %'t F. Piul Bonnett~, Reactor lngineer date bd*dk f/fr/rq David M. Silk, Reactor Engineer
' da/te Approved by:
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Dr. P. K. Eapen,' Chief, Special Test date Program Section, EB, DRS'
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Inspection Summary:
Routine Unannounced Inspection on February 27, 1989 -
l March 16,_1989 (Inspection Report No. 50-353/89-13)
Areas Inspected:
The preoperational test program implementation, l
'preoperational test procedures, preoperational test results, and the QA/QC involvement in the preoperational test program. The specific test procedures
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reviewed are provided in Attachment A of the inspection report.
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Results: No violations were identified.
l Three unresolved items were identified.
The first two unresolved items were to address inaccurate' labeling of a Control Room Temperature Recorder and
inadequate control of the HPCI Lube Oil Supply Valves.
The third unresolved item discusses the inadequate testing of the HPCI Lube Oil Return temperature recorder.
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8905030193 890425
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Details 1.0 Persons Contacted 1.1 Philadelphia Electric Company A. Beard, Startup Engineer
- W. D. Bradley, QA Engineer J. M. Corcoran, Startup Supt., Support M. Decker, Startup Engineer D. A. Entrolizo, QA Engineer K. Fleming, Startup Engineer
- F. J. Ginfrida, Lead Field Engineer
- J. A. Hutton, Startup OPS. Coordinator
- W. L. McCullough, Project Startup Engineer
- K. W. Meck, QA Assistant Supt.
- J. Nagle, Test Review Board Chm.
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- R. L. Payne, QA Engineer B. Simmons, Startup Engineer T. G. Szonntao, QA Engineer G. D. Tepper, Elect. Const. Engineer
- W. T. Ullrich, Unit 2 Startup Manager H. R. Wiegle, Startup Supt., Ops.
M. Wismer, Startup Engineer 1.2 U. S. Nuclear Regulatory Commission R. L. Fuhrmeister, Resident Inspector
- R. A. Gramm, Senior Resident Inspector
- T. J. Kenny, Senior Resident Inspector
- Denotes those present during exit meeting held on March 16, 1989.
2.0 Preoperational Test Program 2.1 Preoperational Test Procedure Review (70307, 70304, 70305, 70340, 70361,70350)
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
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Initial conditions
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Attainment of test objectives
Test performance documentation and verification
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
The inspector reviewed a preliminary copy of Specification 8031-C-112,
" Specification for Primary Containment Structural Integrity Test for the Limerick Generating Station Units 1 & 2."
Included in this' review were supplement I to specification 8031-C-112, and Supplements II &
III to test procedures 1A-59.2 & 2A-59.2.
The review assured that commitments relative to the following reference documents were incorporated into the test procedures:
(1)
U.S. NRC Regulatory Guide 1.18, Rev. 1, " Structural Acceptance Test for Concrete Primary Reactor Containments" and alternate approaches to the Reg. Guide described in the Limerick FSAR Section 3.8.1.7.
(2) ASME B&PV Code,Section III, Division 2, Article CC-6000, July 1980 edition.
(3) Limerick FSAR.
The ASME B&PV Code, Section III: Division 2, Article CC-6241,
" Predictions Required Prior to Test" states, in part, that " Acceptance limits shall.tae provided for each pressurization increment for all devices that, in the judgment of the Designer, - re necessary in order to permit a determination that the test may proceed safely to the next increment of increased pressure." The procedure reviewed did not provide any acceptance limits for determining if the test may proceed safely.
The inspector discussed this observation with the designer. Step 6.4.1, Note B, was added to test procedure 2A-59.2 to address this concern.
The inspector found the action taken adequate and had no further questions concerning the Structural Integrity Test Procedures.
The inspectors did not have any questions on the other procedures reviewed. No noncompliance were identified by the inspector within the scope of this inspection.
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2.2 Test Witnessing (70313, 70432, 70315, 70440, 70317, 70448, 70454, 70435,70460,70450,70434)
The inspector witnessed selected steps of the procedures listed in Attachment A and the following were verified:
Overall crew performance
Use of latest revised and approved procedure by test personnel
Designation of one person in charge of conducting a test
Availability of sufficient test personnel to perform the tests
Coverage of test prerequisites
Use of acceptance criteria to evaluate test results
Supporting systems are in service
In-service status of calibrated special test equipment required
by the test _ procedure Adherence to the requirements of the test procedure during the
tests Timely and correct action by test personnel during the tests
Data collection for final analysis by test personnel
The inspectors witnessed selected steps of the Preoperational Test Procedure 2P-56.1, Rev. O " Reactor Manual Control System."
Procedure step 6.4.1.1(13) requires in part to verify the " ROD AND DETECTOR DISPLAY MODULE HI TEMP" alarm is clear.
The inspectors witnessed that the startup test engineer performing this test failed to verify that the alarm had cleared.
The inspectors pointed this out to the Startup Test Engineer.
The step was repeated in accordance with the procedure.
The inspectors discussed the above observation with the Assistant QA Superintendent. The QA Superintendent conducted an audit on the
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performance of this Preoperational Test.
This audit did not identify any unsatisfactory conditions. The inspector concluded that this was an isolated occurrence and had no further questions.
While observing Local Leak Rate Testing (LLRT) the inspector observed-a pressure test gauge (25-7584) located on the leak rate test rig, with an expired calibration due date.
The inspector verified that
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this pressure gage was not being used to collect data.
The inspector notified the Test Engineer that using the pressure gauge was not in compliance with Administrative Directive 6.9 " Test Equipment Control."
The Test Engineer promptly replaced the pressure gauge with a cali-brated gauge. The inspector observed that each LLRT requires the Test Equipment Calibration dates recorded in the procedure.
Recording of the Calibration due dates is to prevent out of calibration test equipment from being used for data collection.
The inspector investi-
gated the Test Equipment Control program and found it to be in
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compliance with the Administrative Directive 6.9.
The inspector had no additional concerns or questions on the licensee's control of Calibrated Test Equipment.
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During.the course of this inspection, the inspectors witnessed
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Startup Test Engineers performing a number of preoperational tests.
The. inspectors found the Startup Engineers to be experienced and knowledgeable in conducting preoperational tests.
Tests were conducted in accordance with approved procedures and all members of the test teams were provided with the appropriate sections of the test being performed. Test equipment was properly installed and
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used.
The inspectors verified that important system performance functions were adequately tested and-the results were collected and recorded-in accordance with the applicable Administrative Directives.
No violations were identified by the inspector.
2.3 Test Results Evaluation (70400)
The test procedures listed in Attachment A were reviewed to verify:
An adequate evaluation of test results is performed
The test results are either within acceptance criteria or
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properly dispositioned All Preoperational Test related Regulatory Requirement or
licensing commitments have been performed Administrative practices in maintaining proper test discipline
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'concerning test execution, test alteration, and test records are' effective The the licensee is following procedures for review, evaluation,
and acceptance of test results While reviewing tlm results of preoperational tests, the inspector noted that the labeling on temperature recorder TR-56-2R605 was not
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correct. A number of the points which provide input to the multipoint recorder were either missing from the label completely, labelled as the wrong point,-or poorly described. This recorder is used to record fuel pool heat exchanger inlet and outlet temperatures, RHR heat exchanger cooling water outlet temperature, RHR heat exchanger inlet temperature, and lubricating oil temperatures for the HPCI turbine l
and pump. The RHR, HPCI, and fuel pool cleanup and cooling system
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preoperational test were completed. However, the errors in labeling
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of TR-56-2R605 were not identified during the technical tests or
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l preoperational tests for these systems.
The licensee supplied the inspector with the proper identification of recorder points for l
TR-56-2R605 at the exit meeting. The licensee stated that the labeling
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will be corrected. The impact of this mislabeling on the preoperational test data for RHR, HPCI and fuel pool cleanup and cooling system was not fully investigated by the licensee. This concern and the installa-tion of the correct labeling will be tracked under unresolved item (50-353/89-13-01). The labeling of the similar Unit No. 1 Temperature Recorder was found to be correct.
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The inspector. observed while reviewing sections of the HPCI pre-operational test that the pump bearing return temperatures (TE 268 A, B, C) were not recorded from temperature recorder (TR-56-2R605). -In addition, HPCI pump bearing return temperatures were not recorded using TR-56-2R605 during the HPCI technical test, bearing temperatures were collected using the process computer during this test. The recording of the HPCI pump bearing oil return temperature provides vital _information to verify the operability of the HPCI pumps. As such, this instrumentation is required to be verified operational during the initial test program. Testing of this instrumentation will be followed under unresolved item (50-353/89-13-02).
On March 2, 1989, the inspector attended a Test Review Board (TRB) meeting. The meeting was held to review the test results of
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Preoperational Test Procedure 2P-16.1, Rev. 0, "RHR Service Water System." The inspector found the review conducted by the TRB to be detailed and thorough.
Each member's concerns were resolved prior to approving the test results package.
This meeting met all aspects of Administrative Directive 2.4 " Test Review Board".
The inspector found that for the test results reviewed, the Regulatory Requirement and Licensing Commitments relevant to the preoperational test procedures were being met.
Test packages reviewed were found in good order, and in ace ~ dance with the Administrative Directives on
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Test Procedure implementation and control. All the test results reviewed were either acceptable or properly dispositioned.
No violations or unacceptable conditions were identified.
3.0 QA/QC Interface The QA Audit and Surveillance Reports, listed in Attachment B and QA/QC involvement with the Preoperational Test Program were reviewed. All the reports reviewed had satisfactory findings by the licensee QA/QC organization.
4.0 Plant Tours (70302)
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, preoperational tests in progress, and housekeeping.
An observation was made during a plant tour of the HPCI pump, concerning the HPCI Lube 011 System. The observation is common to both Unit No. I and Unit No. 2.
The lube oil supply-lines to the turbine bearings, governor and coupling ends, and the supply to the pump bearings and thrust bearing, have ball valves in them. These valves do not have identification tags.
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' These supply valves are not located on IS55.1.A Check Off List (COL)
" Equipment Alignment for Automatic Operation of HPCI System" (other throttle valves such as 56-IF058, HPCI Vac. Tk. Cond. PP. Disch.'VLV. are located on'the COL). The lube oil supply valves are also not shown on P&ID M-56 HPCI" Pump / Turbine. The licensee did indicate at the. exit meeting that i
ST-6-055-230-1, Rev. 9, "HPCI Pump, Valve and F1ow Test," does require the performance of S55.9A " Routine Inspection of HPCI System." Procedure S55.9A, Rev. 6, Step 8.10.2 does require oil supply pressures be taken. This pro-cedure does not indicate how to obtain these supply pressures.
The inspector found that the HPCI lube oil supply valves were not properly _ controlled.
The tagging and additional administrative' controls required to address this problem will be followed under unresolved item (50-353/89-03-03).
5.0 Unresolved Items-Unresolved items are matters'about which more information is required in order to ascertain whether they are acceptable items or violations.
Unresolved items are discussed in paragraphs 2 and 4.
6.0 Exit Meeting
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The findings of the. inspection were discussed with licensee representatives during the course of the inspection and presented to
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licensee management-at the March 16, 1989 exit interview (see paragraph 1 for attendees).
At no time during the inspection was written material provided to the licensee by the inspector.
The licensee did not indicate that proprietary information was involved within the scope of this inspection.
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Attachment A Inspection Proc. No.
Description Scope 2P2.1.
125 VDC Safeguard Power System TW 2P16.1A&B RHR Service Water System PR 2P18.1 Instrument Air System TRE 2P35.1 Fuel Pool Cooling / Cleanup System TRE 2P39.1 Condensate Demineralized System TRE 2P54.1A&B Emergency Service Water System PR,TW
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Control Rod Drive Hydraulic System TW 2P56.1A'
Reactor Manual Control System TW 2P58.1 Reactor Protection Systen TW 2P64.1 Reactor Recirculation System TRE 2P78.1 Source Range Neutron Monitoring System TW 2P78.3 TIP Calibration System PR 2P80.1 Reactor Vessel Instrumentation System TW l
2P81.11 Fuel Handling System TRE 2P83.1 Main Steam System TW 2P83.2 Auto Depressurization System TW LLRT's ST-1-LLR-11, 141, 391 TW Inspection Scope Notations 1.
PR - Preoperational Test Procedure Review 2.
TW - Preoperational Test Witnessing
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TRE - Test Results Evaluation I
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Attachment B QA Audit Reports Reviewed Report No.
Subject UnSat. Findings 2S-160 Test Jack and Bypass Switch Installation None 25-161 Preoprational Test Personnel Qualifications None 2S-167 Prevention of Electromagnetic Interference None I
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