ML20112E449
| ML20112E449 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/11/1985 |
| From: | Gunther W, Higgins J BROOKHAVEN NATIONAL LABORATORY |
| To: | |
| Shared Package | |
| ML20112E442 | List: |
| References | |
| GL-84-15, NUDOCS 8503260562 | |
| Download: ML20112E449 (20) | |
Text
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3 ENCLOSURE BROOKHAVEN NATIONAL LABORATORY TECHNICAL REVIEW REPORT DATES OF INSPECTION: January 21-25, 1985 ORGANIZATION:
Limerick Generating Station (LCS)
LICENSEE:
Philadelphia Electric Company (PECo)
LOCATION:
Limerick, PA
/I BNL TECHNICAL SPECIALIST:
[ L Cgggins (Date)
LM A xd) zhi/er W. E.' Gunthef' (Date) 8503260562 850321 PDR ADOCK 0500 2
0
r-2 1.
PERSONNEL CONTACTED The following PECo personnel were contacted during the course of the on-site review of the AC and DC Electric' Power Systems.
R. Atkinson-Mechanical Engineering R. Brown' Maintenance J. Corcoran QA D. Clohecy QA J. Cotton Maintenance R. Dungey Maintenance
-A. Diederick Mechanical Engineering J. Doering Operations G. Edwards Operations C. Endriss Regulatory Engineering F. Gibson QA D. Helwig Mechanical Engineering H. Hansell-Mechanical Engineering J. Harding Field Engineering i
C. Harmon QA M. Haag Electrical Engineering G. Lauderbach QA G. Leitch Plant Superintendent M. McGill Mechanical Engineering W. McFarland Mechanical Engineering C. Patton
. Field Engineering W..Sproat Electrical Engineering
.E. Troy Maintenance The reviews also discussed issues with various operations, test, mainte-nance, engineering, and QA personnel. Additionally, the following NRC person-nel were consulted prior to and during the inspection:
W. Borchardt, J.
Beall, and J. Wiggins.
i-2.
DOCUMENTS REVIEWED The following materials or documents were reviewed:
1)
Limerick Final Safety Analysis Report (FSAR), Rev. 34 2)
Limerick Probabilistic Risk Assessment (PRA) 3)
Limerick Technical Specifications (Tech. Specs.)
'4)
Emergency AC/DC Power System Descriptions 5)
Off-Normal, Operational Transients, and Trip Procedures 6)
PECo Response Package for NRC Generic Letters 84-15 and 81-04.
7)
Limerick Safety Evaluation Report 8)
IEEE Standard 279-1971, " Criteria for Protection Systems for Nuclear Power Generating Stations"
3 9)
IEEE Standard 379-1972, "IEEE Trial-Use Guide for the Application of the Single-Failure Criterion to Nuclear Power Generating Station Protection Systems"
- 10) Limerick Electrical Engineering corespondense, E. F. Sproat to G. M.
Leitch, Superintendent regarding Preop Test Results, IP2.1 and IP2.2.
- 11) DC Load Profile, Bechtel Document Control No. 181659, BLP 32975
- 12) Limerick D. C. System Load and Short Circuit Studies, 3/84 Document Control N. 178802 o
- 13) Limerick DC Load Study Calculation 6600E.09, 6/14/83.
- 14) Limerick Maintenance Procedures a) PMQ-095-001 Preventive Maintenance for Q Listed Battery Chargers b) PMQ-095-002 Preventive Maintenance for Q Listed Batteries c) PMP-095-004 Preventive Maintenance for Non-Safety Related Battery Charger Operation & Maintenance d)
PMQ-095-006 Preventive Maintenance for Q Listed Battery Cell Replacement e)
M-030-002, Rev.'O Diesel Engine 18-month Examination and Maintenance f) M-030-001, Rev. 1 Diesel Generator 18 Month Examination and Maintenance
- 15) Limerick Operating Procedures:
a) S92.1.N(Col-1) Rev. O, Equipment Alignment for 1A Diesel Generator Operation b)
S92.1.A, Rev. 1, Energization of D11 Safeguard Bus c)
S92.2.A, Rev. O, De-energizing a 4ky Safeguard Bus d)
S92.6.A, Rev. 2, Transfer of a 4kv Safeguard Bus from 101 to 201 and vice versa.
e)
S92.3.A, Rev. O, Racking 4kv Breakers In/Out of Compartments f)
S92.9.A, Rev. O, Normal Line-up of 4ky Safeguard Breakers g)
S93.1.B, Rev.1, 480 VAC Non Safeguard h)
S93.1.B, Rev. O, 480 VAC. Safeguard Motor Control Center Energization 1)
S93.8.A, Rev. O, Reenergizing a 480 VAC Load Center Following a Load Center Trip j)
S91.1.J, Rev. 1, Energization of 101 Safeguard Transformer k)
S35.8.0, Rev. 0, Placing 500/220 kv Substation Auto transformers (4A &4B) in Service from the 500/220 kv Substation Control Houses 1)
S92.9.N, Rev. O and proposed Rev. 1 Routine Inspea
- w. a.
'asel Generators a)
S92.1.N, Rev. O and proposed Rev. 1, Diesel Generator Set Up for Automatic Operation n) S81.1.1A (COL-3) Equipment Alignment for Startup of D/G Enclosure HVAC o) S.11.1A (COL-1) Emergency Service Water System Lineup
c 4
- 16) 1 Surveillance Procedures a)
ST-4-095-921-1, Rev. 1, Div. I, 125/250.VDC Safeguard Battery 18
-Month Inspection b)
ST-4-095-931-1, Rev. 1, Div. I, 125/250 VDC Safeguard Battery Performance Test c)
ST-6-095-911-1, Rev. 2, Div. I, 125/250 VDC Safeguard Battery Quarterly Inspection
~d)
ST-4-095095101, Rev. 1, Div. I, 125/250 VDC Safeguard Battery 18 Month Service Test e) -ST-6-095-1, Rev. 4, Div. I, 125/250 VDC Safeguard Battery Weekly Inspections f)
ST-6-092-312-1, Rev. 3 and 4, Diesel Generator Operability Test
-(Monthly)
- 17) Preoperational Test Results Packages a)
IP-2.1 125 Volt Safeguard DC Power System b) 1P-2.2 125/250 VDC Safeguard Power System, Division 1,2 c)
IP-28.1 D/G Enclosure HVAC System
- 18) Selected Electrical Drawings, Logic Drawing and Piping and Instrumentation Diagrams (P& ids) 19)
U.S. NRC Regulatory Guides 1.93, 1.108 20)
IEEE Standard 387-1972 and 1977 - Criteria for Diesel Generator Units Applied as Standby 1 Power Systems for Nuclear Power Generating Stations
- 21) Operations and Maintenance Manual for Fairbanks-Morse Opposed Piston Engines, Colt. Industries
. 22) Selected U.S. NRC NUREG Documents in Pertinent areas
- 23) NSAC-79, April,1984, A Limited - Performance Review of Fairbanks Morse and General Motors Diesel Generators at N clear Plants u
- 24) C&D Battery Charger Instruction Manual - C&D Batteries Division, Model ARR 130 K 400.
25)
IEEE Standard 450-1975, IEEE Recommended Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating Stations and Substations
-26)
IEEE Standard 485-1978, IEEE Recommended Practice for Sizing Large Lead Storage Batteries for Generating Stations and Substations
- 27) Annunciator Response Cards for DC and Emergency AC alarms in the control room
- 28) PORC meeting Hinutes 84-74, 9/26/84
- 29) Emergency Procedures:
a)
E-1, Rev. O, Loss of All AC Power (Station Blackout)
'b)
E-10/20, Rev. O, Loss of Offsite Power
C 5
'3.
-SCOPE:
During the reviews of the AC and DC electric power systems the following areas and items were addressed:
3.1 Preoperational Testing This included battery, battery charger capacity testing, and D/G ventila-tion testing and comparison to FSAR and Technical Specification requirements.
3.2 System' Hardware Review This included a detailed walkdown of the system consisting of the Battery rooms, AC and DC switchgear rooms, Cable Spreading Room Inverter Rooms, Power i
Generation Equipment Area, the Control Room, Offsite Power lines and switch-yards and Diesel Generator Rooms 3.3 Operating Procedure Review l
(.
This included normal line-up breaker check off lists, emergency proce-dures, alarm. response cards, surveillance test procedures, and operating procedures.
3.4 Maintenance Procedures Review l
This included preventive maintenance,_ surveillance' test procedures, and refueling cycle maintenance procedures.
L 3.5 Review of Above Items
['
All of-the above items were reviewed against the AC and DC Electrical system failure modes identified by the PRA to be of most significance to plant safety.
.4.
PLANT TOUR As part of the system review, a number of plant areas were toured to ob-serve equipment in operation and to verify procedural steps and operator in-structions. The following areas were observed:
Division 1-4 Battery Rooms, Divisions 1-4 Auxiliary Switchgear Rooms, Auxiliary Equipment Room, Power Gen-
- eration Enclosure, Cable Spreading Room, the Control Room, the offsite power incoming power supply lines, the 500 KV and 220 KV switchyards, the 33 KV l
backup power arrangement, the various major transformers, and all four Unit 1 Diesel Generator Rooms. These locations were generally in good condition with no abnormal conditions observed, except as follows:
l 1.
In the A and B Battery rooms (Div.1 & 2), paper had been placed un-der the battery racks due to acid dripping from the cells. The source of this acid may be from spillage during refilling of cells, or from testing for specific gravity. There was no indication of cell cracking, and the cells appeared to be in ' excellent overall I
condition.
i
c:
6 2.
A largo amount of the bolting on the 4 ky.switchgear cabinet doors was loose. This bolting is required to be tight in order to ensure the seismic qualification of the cabinets. In a number of instances the bolts could not be immediately tightened due to missing clips in the panels into which the bolts "are threaded. This discrepancy was corrected before the end of the inspection, but needs continuing li-censee attention to prevent recurrence.
3.
'A large metal extension piece was observed loose inside a 4 kv switchgear cabinet.
4.
Floor grating was observed to be broken and loose on the second level
.of Diesel Generator (D/G) rooms D-13 and D-14.
'5.
The'D/G. ventilation panels had no permanent labels for the D/G venti-lation system fan and damper indicator lights.
- 6. EA number of vents for diesel waste oil systems, located on the D/G Building roof, were taped shut. The licensee removed the tape to
~
make the vents functional.
7.
Some debris was observed in "out of the way" places in D/G rooms D-11 and D-II.
- 5. 'DC SYSTEM REVIEW
-The purpose of the DC Electrical System is to provide a reliable source of on-site power to pumps, valves, instruments, annunciators, and control cir-cuits upon a loss of AC power for a time adequate to safeguard the plant until power is restored to the AC buses.
The safeguard-DC distribution system consists of four independent battery systems. The Division I cnd II 125/250 VDC safeguard systems each consist of two 125 V batteries arranged in series so that 250 volt loads for HPCI and RCIC can also be supplied. In addition, the system has a neutral lead which 1 taps between the two 125 Y batteries ' to supply the required 125 V loads on each division bus. The Division III and 'IV 125 VDC systems each consist of one 125 V battery and associated charger. Each of the four 125 VDC systems
~
provides the control and motive power for its associated class 1E AC power division: 4 kv switchgear, 480 volt load centers and diesel generator control power. Each battery is designed to carry the essential loads continuously for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in the event of a. total loss of AC. power. Procedurally, this time is extended by shedding various non essential loads and by controlling DC system operation to avoid excessive cycling of equipment. The charger associated with each division-is designed to supply the required loads under all plant.
. conditions while recharging a completely discharged battery within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
6.
DC~PREOPERATIONAL TESTING The primary oojective of the preoperational test program for the DC elec-trical system was to verify the capability of the batteries and battery char-gers to supply required loads over the time frame specified while maintaining a predetermined voltage limit. This objective addresses a relatively high probability PRA fault mode. The data reviewed met the acceptance criteria of
P 7
the test and demonstrated that the licensee review and approval process was
- acceptable. All FSAR and ' Technical Specification (Tech Spec) commitments were met with the following exceptions:
1.
Preoperational Test (Preop Test) 2.1 tested the capability of the i
batteries to meet a load profile consistent with post accident condi-
[
-tions.
A revised FSAR table was included in the test package to dem-onstrate the source of the imposed test values. However LDCN FS-414, dated 6/20/83 and used as the source document, was later revised by Bechtel in March, 1984. For batteries 1A2D101, IBID 101, and 1B2D101, the March 1984 loading exceeded the preop test values even though they had been chosen " conservatively higher than the LDCN figures to allow for both instrument inaccuracies and minor future revisions of the load cycle." The March, 1984 revised loads were incorporated in-to the Tech Specs, and thus battery capability to satisfy this higher load profile must be demonstrated every 18 months.
Because the preop test was performed just prior to fuel loading, the licensee is using the preoperational test results to satisfy the surveillance require-ment.(4.8.2.1.d.2).
The concern expressed by BNL to the licensee was that the Tech Specs did not appear to be successfully met since the loads specified in Tech Specs are higher than what was demonstrated by the preop test.
At the exit meeting, a Bechtel evaluation of the situation was pre-seated, Document BLP-32975 dated 4/24/84, which indicated that based on the voltages existing at the end of the test as well as voltages obtained through a mathematical model, adequate battery capacity-existed to meet Tech Spec requirements. In addition, on 1/29/85, copies of the PORC meeting minutes dated 9/26/84 were received indi-cating PORC acceptance and approval of the Bechtel analysis.
As a result of the review of this additional material, it is felt that the battery capability adequately meets the requirements as set forth in the~FSAR and Technical Specifications. The existing sur-veillance procedure addresses the new Tech Spec load profile and is scheduled to be performed at 18 month intervals.
l 2.
Battery charger testing performed in preop test 2.1 consisted of a
[
series of steps to verify that the charger could recharge the battery from a full discharged condition while supplying " normal loads".
The FSAR, 8.3.2.1.1.3 requires-that the charger be capable of eupplying
" normal operating, shutdown or post accident DC system loads" while restoring the batteries to a normal voltage within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This position is also reflected in a licensee response to an NRC question in the FSAR (page 430.57-5). Information provided by the licensee at the exit meeting and via telecon on 1/28/85 failed to resolve this concern.
7.
OPERATING PROCEDURES The station operating procedures were reviewed and discussed with Opera-ting Section Supervision. Of primary concern in this area was operator re-sponse to control room alarms and the accuracy of the procedures for de-ener-gizing and re-energizing safeguard buses. The procedures were found to be comprehensive and accurate with one exception:
8 Some of. the DC system related alarms are common alarms with multiple in-puts. ' This requires a plant operator to be dispatched to a local panel to observe a local annunciator panel. As required in the FSAR and by good operating practice, alarm response cards (ARCS)for the safety related local alarms must ' be available to the operator (FSAR 13.5.1.19).
Of par-ticular concernuis guidance to the operator for ventilation problems which could make portions of the DC system inoperable if they were to fail. The tech spec operability definition for safety related systems requires that 'all auxiliary and supporting systems also be operable. In these cases, a reference in the ARC to tech spec operability would be appropriate.
The. licensee stated that ARCS for local panels were under development and would be completed'in the near future.
8.
DC SYSTEM SURVEILLANCE TESTING AND MAINTENANCE PROGRAM The DC Electrical system surveillance testing is currently being imple-mented.with the exception of certain refueling interval tests which were de-ferred as a result of successful completion of the preop testing. The proce-dures were verified to meet the Tech Spec requirements.
Administratively, it was not initially clear how the licensee would handle a situation where category B limits were exceeded on a safeguards bat-tery. Tech Specs do not require the battery to be declared inoperable in this
- case,- however, the parameter must be brought into normal limits within 7 days. The licensee has a program for tracking conditions which require enter-ing a Tech Spec action statement (LCO log)'and, after discussion with shift supervision, stated that exceeding the category B limit would be tracked in the same manner as an LCO. It was also pointed out by the licensee that the surveillance - test _ procedure could not be approved. by - the Regulatory Engineer until the out of spec. condition was corrected._ D1is item is therefore con-sidered to' be adequately addressed.
The Preventive Maintenance (PM) ProgramLwas also reviewed to ensure that vendor recommendations for periodic maintenance were being addressed. PM for batteries, chargers,- inverters and circuit breakers, is covered by detailed procedures and scheduled by an advanced computer program which covers virtu-ally all plant equipment. In addition, the administrative controls to be used
~ when implementing PM were also reviewed. The DC power PM program is compre-hensive and when. implemented in full will satisfactorily address manufacturer recommendations and industry good practices to ensure reliable DC system operation.
9.
AC OFFSITE POWER SYSTEM The AC Offsite -Power Systems as described in the Limerick FSAR and SER were reviewed. The various areas described in paragraph 4 were toured to observe equipment conditions, equipment lineup, physical and electrical sepa-ration, and compliance with commitments. Selected operating procedures for the. systems were also. reviewed, as well as an approved design change package for-the 33 KV power system. With the exception of the below three items no discrepancies were identified.
y 9
- 1...The FSAR describes the two physically and electrically independent offsite. power sources as from the 500 KV and 220 KV systems. It then goes on in paragraph 8.1.9 to describe a backup third independent offsite source which can be connected to supply ESF Loads. _ Paragraph 8.1.5.1.c, design bases, states that.on loss of.one of the offsite power sources, a third separate power source can be connected within a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period to meet Reg. Guide 1.93.
And paragraph 8.1.5.2.d states that outage of one startup'and/or. safeguard transformer does not jeopardize continued plant operation, because the spare third offsite source transformer can be connected within the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period to meet Reg. Guide 1.93.
Paragraph'8.2.1.1 describes,the connection
.of the 33 KV power source, if needed, and states the control and pro-tective relay wiring would be previously installed.. Discussions with PECo Electrical Engineering personnel confirmed that in order to meet the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> installation time, that relaying and control power wiring would need'to be already installed.
It was also noted that there was no plan or procedure for how this connection of the spare power L
source-or spare transformer would take place and that the power to the 33 KV oil-cooled circuit breaker auxiliaries was not completed.
Hence it was concluded that the arrangement for the 3rd offsite power
-source from the 33 KV system was not completed to the extent commit-ted in the.FSAR (i.e., so'that'it could be used within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />).
2.
Tech-Spec 3.8.1.la states that'the plant'must have as a minimum 2 physically independent circuits between the offsite transmission net-work and onsite.. Utility contingency' plans to use the 33 KV system as a backup in the event of failure of the 500 kv switchyard do not appear appropriate, since the 220 KV and the 33 kv sources are not
. physically independent.- Part of the 33 KV feed-to the plant trans-former goes through the_220 KV switchyard and the final 33 KV pole is
-immediately outside of the 220 KV switchyard fence.
- 3. L A discrepancy was noted between the electrical drawing E-1, Rev. 12 and the switchyard lineup procedure, S35.8.0, Rev. O.
The procedure.
calls for the 13.2 KV disconnect switch No. 4B7 to be shut while the drawing shows it. blocked open. During the tcur the switch was shut
'in accordance with the procedure. The licensee stated that drawing would be corrected to agree with actual practice.
- 10. DIESEL GENERATOR REVIEW 8
10.1 Discussion The Emergency Diesel Generators (D/Gs) at Limerick were reviewed in de-tail. Items reviewed included: design, operation, maintenance, failure re-ports, auxiliary systems, procurement of spare parts, physical condition, testing, training, and record keeping. Limerick has four D/Gs per unit, one for each electrical safeguards division. Each D/G is driven by Colt / Fair-banks-Morse Opposed Piston, 12 cylinder engine, is rated at 2850 KW, and is
-contained in a separate room. The overall program at Limerick to ensure reli-able D/G operation appeared well thought out and appropriately implemented Details of specific areas reviewed along with the findings identified are described below.
e; e
10 10.2 Ventilation The D/G intake air system, exhaust gas system, and room ventilation sys-ten were reviewed. FSAR Section 9.4.6.2 states that each D/G room has two 50%
capacity vane axial ventilation fans, each with a discharge damper that opens on fan start. With the exception of the four below items no discrepancies were identified.
- 1. - ' Procedure S81.1A (col-3), Rev. O, states that the ventilation switch lineup is one fan in auto and 1 in standby. The tour made of all four D/G rooms on 1/23 found both fan switches in auto for 3 out of 4 D/G rooms. The licensee confirmed that the procedure line up was proper and corrected the actual switching.
2.. 'During the tour on 1/23/85, it was noted that fan no. 1EV-512 in D/G room D-11 had an Equipment Trouble Tag on it, dated 12/14/84. The tag had MRF# 8405672 on it, stated that the fan will not stay run-ning, and indicated that the fan was "INOP".
The fact that the fans were 50% capacity and are required for D/G operation would indicate that the 'D/G would be inoperable also. However, the utility had not declared the D/G inoperable and had not performed any additional re-views or analyses to determine the appropriate D/G status. After the concern was identified, the licensee's engineering organization per-formed an evaluation and stated that for outside temperatures up to 75'F one fan will suffice. Above 75'F, two fans are required. The licensee stated that this evaluation would be formally transmitted to the station for appropriate use.
~3.
During the tour on 1/23/85, in D/G room D-14, it was noted that the discharge damper light for fan IDV512 was red (indicating open) and the lite for fan 1HV512 damper was green (indicating closed).
~
Neither fan was running. The dampers have no local position indica-tors on their actuators.
4.
Observation of the D/G exhaust pipe arrangement and the proximity of the Reactor Building Ventilation Intake led to questions about the potential for D/G exhaust entering the Reactor Building to the possi-ble detriment of personnel, and standby gas treatment system fil-ters. The licensee stated that exhaust smoke entering the Reactor Building has been a problem, but that they are actively pursuing a redesign of the D/G exhaust to eliminate-the problem.
10.3 ' Maintenance The planned maintenance and maintenance procedures for the D/Gs were re-viewed to determine if they met FSAR commitments, vendor reconumendations, and good industry practice. The practices for D/G spare parts and services pro-curement were also reviewed. The program overall appeared comprehensive. A
- few specific deficiencies were noted as follows:
1.
The refueling cycle maintenance procedures referred to a CARD 0X sys-tem not in existence at Limerick and they did not contain all of the vendor recommended checks (e.g., checks of timing gears, end float, vertical drive bearings, generator bearings, and a foundation hold-down bolts). The licensee' agreed to correct these items.
r.
11.
2.
A procedure for longer ters (e.g., 5 year frequency) maintenance had not yet been generated. The licensee added this to his procedures list.
13.~
Not all of.the vendor recommended operational checks and inspections-(at -a daily, weekly, or quarterly frequency) were being performed.
' The majority of these checks are outlined in Limerick procedure S92.9.N, however, the, procedure is not being routinely implemented.
Additionally, one recommended ites, not contained in any procedure, is a weekly or zbiweekly wipe down and cleaning of the unit in order to remove oil, fuel, and water and in order to note any minor leaks for. repair.
10.4-Operation and Physical Condition The physical condition of the D/G set, its auxiliaries, and related hard-
- ware in the diesel rooms was observed both with the diesels running and se-cured. All.four D/G rooms were inspected and D/G-12 was observed in operation at' full load. D/G-12 appears to run smoothly and carries load steadily. The overall condition of the D/Gs and their rooms was good. Some discrepancies were identified as follows:
1.
D/G-13 and 14 were noted to have a few loose or disconnected tubing clampsDon the diesel engines.
2.
The FSAR on page 430.47-4 describes the D/G instrument panel, which is skid-mounted. The panel's supports are mounted in a cradle with isolation springs to dampen engine vibration and protect the gauges.
During the tours it was noted that the cradle and springs did not appear properly adjusted, since there was little or no clearance to
-allow downward movement. The mount drawing only gave an overall di-mension and not the specific clearance in question. By phone conver-sation the vendor stated that some clearance should exist and pron-ised further details.
3.
There are a number of normally closed instrument panels in the D/G rooms which contain relays and instruments. FSAR page 430.47-3 de-scribes these as containing " fully-gasketed, dust-tight doors" in order to ensure reliable operation. _ During the week a number of these panels were ~found with their gasketed doors either unfastened or partially open.
4.
Almost immediately af ter the start up of D/G-12 the room became smokey and the smoke detector alarm sounded. The operator had placed both vent fans in auto so that both would come on with the D/G start to help alleviate the smoke. However, the alarm still sounded and in fact stayed sealed in during the full one hour D/G run. It was noted that smoke or exhaust gas was coming from the D/G exhaust manifold area. Operations personnel stated that D/G-12 routinely gives a smoke alarm, while the other D/Gs do not.
This continuous smoke alarm from D/G operation is a concern since it could mask a true fire smoke alarm.
12 Procedure S92.1.N (col-2), step 146 puts the D/G room Local-Remote
_5.. Selector Switch _.in the " Local" position, which is incorrect and would
-not allow a control room start of the D/Gs. The' actual switches were found in the correct " Remote" position. The licensee stated that switches should be in the " Remote" position and would research why the procedure specified the " Local" position.
.10.5 Surveillance Testing
._ The monthly D/G Surveillance Test performed to meet Technical Specifica-tions and Reg. Guide 1.108 was observed. During this test diesel and diesel auxiliaries start times and performance, are tested. The D/G is also run for one hour at rated load. The operator performing the test and running the D/G was well-trained and very knowledgeable about diesel operation. The test was performed successfully and in accordance with procedure ST-6-092-312-1.
The procedure was verified to meet regulatory requirements and commitments. Two items relating to this test procedure were identified.
i 1.
FSAR paragraph 8.1.6.1.20 states that periodic testing of D/Gs will be in conformance with Reg. Guide 1.108.
Paragraph C.2.c.(2) of Reg. Guide'1.108_ specifies that the monthly D/G test should verify.
that the cooling system functions within design limits. Currently the procedure only checks the cooling system (ESW) pressure is present.
2.
The D/G monthly test run does not currently record diesel operating parameters for comparison with limits and for trending purposes.
This is contrary to standard industry practice and the vendors recom- -
mendations (Operations & Maintenance Manual, Chapter 2, page V.5 and NSAC-79, Appendix G, item 6.c).
10.6 Auxiliary Systems A number of D/G auxiliary or supporting systems _were reviewed including:
-D/G ventilation, fuel oil, lube. oil, starting air, cooling water, emergency service water (ESW), fire detection & suppression, and combustion air. Sys-l tems were generally found acceptable. With the exception of previously dis-cussed items and the one item on ESW below, no discrepancies were identified.
i The ESW to each D/G discharges through a single manual valve (Number 11-1005). It was not clear what the required or the actual position was for this valve, for each D/G.
Specifically:
1.-
The Limerick PRA AC power fault trees list the valves as normally open-fail closed.
2.
Procedure S.11.1A (col-1) states that the valves for the 4 D/Gs are throttled open (2 1/8, 2, 2 1/10, and 2 turns respectively).
3.
Procedure S92.1.N (col-1) states that the valves are open (i.e., full open).
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13 Th' re is no position indication on the valves.
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-_5. 'During the performance of ST-6-092-32 on 1/23/85, the operator adjus-ted the position of the valve from one throttled position to another throttled position.
- 11. ONSITE AC POWER DISTRIBUTION The method of onsite AC distribution was reviewed, including buses, switchgear, transformers, procedures, and indication. The alarms and associ-ated. procedures for loss of individual buses and recovery of the same were re-viewed. Additionally, the Emergency Procedures for Loss of Offsite Power and Loss of'all AC Power (Station Blackout). The individual. bus procedures were comprehensive and easy to utilize. With the exception of the below items, no concerns were identified in the emergency procedures.
1.
Loss of Offsite Power Procedure a.-
Procedure does not reference Offsite Power Tech Spec.
b.
No mention of utilizing backup 33 KV offsite power source.
c.
In step 3.5, the breaker names in the procedure do not agree with the breaker names on the control room panel.
The licensee stated that they were aware of the name discrepancy and intend to
, revise the procedure to correct them.
2.
Station Blackout Procedure a.,
The initial pressure control band is perhaps too small and there is no mention of minimizing the number of SRV openings. (see NUREG/CR-2182).
b.
Step 3.16 does not give details or reference another procedure for the diesel fire pump to Reactor Vessel crossconnect.
. The licensee stated that they intend to modify the procedure to reference another procedure for the crossconnetion.
- 12.
SUMMARY
OF FINDINGS
'12.1 Open Findings l
Below are listed in summary fashion the identified items which were not resolved during the review.
1.
Loose metal components in 4 KV switchgear (para. 4) 2.
Broken. floor grating in D/G rooms (para. 4) 3.
D/G ventilation panel labels (para.4) 4.
Debris in D/G rooms (para. 4) 5.
_ Battery charger load testing less then required (para. 6) 6.
Alarm response cards for local safety related panels (para. 7)
' 7.. Sufficient completion of 33 KV offsite power source (para. 9) 8.
Physical independence of 33 KV and 220 kv sources (para. 9) 9.
Switchyard disconnect position (para. 9)
L
r 14
-10.
D/G vent fan capability and D/G operability (para. 10.2)
- 11. D/G vent fan discharge damper position / indication (para. 10.2)
- 12. D/G exhaust into reactor bldg. ventilation intake (para. 10.2)
- 13. Refueling cycle D/G maintenance procedures (para. 10.3)
- 14.
Vendor recommended D/G operational checks (para. 10.3)
- 15. D/G physical condition discrepancies (para. 10.4)
- 16. Verification of D/G cooling system within design limits (para. 10.5)
-17.
Trending of D/G operating parameters not performed (para. 10.5) 18.
Positioning of ESW throttle valve for D/G cooling (para. 10.6) 19.
Loss of offsite power procedure items (para. 11) 20.
Station blackout procedure items (para. 11) 12.2 Resolved Findings Below are listed in summary fashion the items identified which were cor-rected by the licensee.
1.
Switchgear panel seismic bolting loose (para. 4) 2.
-D/G building vent pipes taped shut (para. 4) 3.
Battery capacity test load' profiles (para. 6) 4.
Tracking when battery category B limits exceeded (para. 8) 5.
D/G vent fan switch lineup (para. 10.2) 6.
Long tern D/G maintenance procedure (para. 10.3)
- 13. Exit Interview The reviewers met with licensee representatives and the NRC Senior Resident Inspector at the conclusion of the Technical Review on January 25, 1985.
At that time copies of handwritten " Preliminary Findings" (attached) were provided. No items were identified as being proprietary in nature.
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