IR 05000353/1989013

Insp Rept 50-353/89-13 on 890227-0316.No Violations Noted. Major Areas Inspected:Preoperational Test Program Implementation,Preoperational Test Procedures,Preoperational Test Results & Qa/Qc Involvement in Test Program

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: IR 05000353/1989013 ML20245G587
References
50-353-89-13, NUDOCS 8905030193
Download: ML20245G607 (9)

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U.S. NUCLEAD. REGULATORY COMMISSION

REGION I

Report N /89-13 Docket N License N 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: Nk //

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games ' 'rapp, Reactor Engineer ll F. Piul Bonnett~, Reactor lngineer Y - 11 - %'t date bd*dk David M. Silk, Reactor Engineer f/fr/rq

' da/te Approved by: bk Dr. P. K. Eapen,' Chief, Special Test II date

Program Section, EB, DRS' l l

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 repor !

Results: No violations were identifie l Three unresolved items were identified. The first two unresolved items were to address inaccurate' labeling of a Control Room Temperature Recorder and 1 inadequate control of the HPCI Lube Oil Supply Valves. The third unresolved item discusses the inadequate testing of the HPCI Lube Oil Return temperature recorde I

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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

• G. Lauderback,'Startup QC Sup * L. McCullough, Project Startup Engineer

• K. W. Meck, QA Assistant Sup *J. Nagle, Test Review Board Ch '

• R. L. Payne, QA Engineer B. Simmons, Startup Engineer T. G. Szonntao, QA Engineer G. D. Tepper, Elect. Const. Engineer

• T. Ullrich, Unit 2 Startup Manager H. R. Wiegle, Startup Supt., Op M. Wismer, Startup Engineer 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, 198 .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 '

• Initial conditions l

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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. (2) ASME B&PV Code,Section III, Division 2, Article CC-6000, July 1980 editio (3) Limerick FSA 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-5 to address this concern. The inspector found the action taken adequate and had no further questions concerning the Structural Integrity Test Procedure The inspectors did not have any questions on the other procedures reviewed. No noncompliance were identified by the inspector within the scope of this inspectio i

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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 procedur The inspectors discussed the above observation with the Assistant QA

, Superintendent. The QA Superintendent conducted an audit on the performance of this Preoperational Test. This audit did not

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identify any unsatisfactory conditions. The inspector concluded that this was an isolated occurrence and had no further question 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 dat The inspector verified that this pressure gage was not being used to collect data. The inspector

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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- 1 gated the Test Equipment Control program and found it to be in '

compliance with the Administrative Directive The inspector had no additional concerns or questions on the licensee's control of Calibrated Test Equipmen _

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During.the course of this inspection, the inspectors witnessed Startup Test Engineers performing a number of preoperational test 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

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test being performed. Test equipment was properly installed and 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 Directive No violations were identified by the inspecto .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 properly dispositioned

All Preoperational Test related Regulatory Requirement or licensing commitments have been performed

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Administrative practices in maintaining proper test discipline

'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

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noted that the labeling on temperature recorder TR-56-2R605 was not 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 {

preoperational test were completed. However, the errors in labeling 1

. of TR-56-2R605 were not identified during the technical tests or  !

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 ]

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 correc l

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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

. 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 packag 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 Test Procedure implementation and control. All the test results reviewed were either acceptable or properly dispositione No violations or unacceptable conditions were identifie .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 organizatio .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 housekeepin 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 tag l

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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 _ controlle 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 violation Unresolved items are discussed in paragraphs 2 and .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 ,

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 inspectio !

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Attachment A Inspection Proc. N Description Scope 2P VDC Safeguard Power System TW 2P16.1A&B RHR Service Water System PR 2P1 Instrument Air System TRE 2P3 Fuel Pool Cooling / Cleanup System TRE 2P3 Condensate Demineralized System TRE 2P54.1A&B Emergency Service Water System PR,TW

- 2P55.1' Control Rod Drive Hydraulic System TW 2P56.1A' Reactor Manual Control System TW 2P5 Reactor Protection Systen TW 2P6 Reactor Recirculation System TRE 2P7 Source Range Neutron Monitoring System TW 2P7 TIP Calibration System PR 2P8 Reactor Vessel Instrumentation System TW l 2P81.11 Fuel Handling System TRE 2P8 Main Steam System TW 2P8 Auto Depressurization System TW LLRT's ST-1-LLR-11, 141, 391 TW Inspection Scope Notations PR - Preoperational Test Procedure Review TW - Preoperational Test Witnessing - TRE - Test Results Evaluation I

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Attachment B QA Audit Reports Reviewed Report N 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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