IR 05000352/1985025

Insp Repts 50-352/85-25 & 50-353/85-06 During May 1985.No Violation Noted.Major Areas Inspected:Followup on Outstanding Items & Selected Low Power Conditions & Plant Tour

ML20127M413
Person / Time
Site:	Limerick
Issue date:	06/18/1985
From:	Gallo R, Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127M370	List: IR 05000352/1985025 ML20127M367
References
TASK-2.F.1, TASK-3.D.1.1, TASK-TM 50-352-85-25, 50-353-85-06, 50-353-85-6, IEB-84-01, IEB-84-1, NUDOCS 8507010219
Download: ML20127M413 (20)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

t 85-25 Report No ,

50-352 Docket No NPF-27 C License No CPPR-107 Priority --

Category A Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Limerick Generating Station, Unit 1 & 2 Inspection Conducted: May 1 - 31, 1985 Inspector: N ) v;,2 M [p!/f iggins ior Resident Inspector Date Other Participatin Inspectors:

J. Grant J. Beall L. Cheung D. Florek Approved By: k R. M. Gallo, Chief, Reactor Projects Section 2A 5 l8. 6 Date Inspection Summary: Combined Inspection Report for Inspection Conducted May 1

- 31,1985 (Report Nos. 50-352/85-25, 50-353/85-06)

Areas Inspected: Routine and backshift inspections by the resident inspector and region-based inspectors of: followup on outstanding items; followup on selected low power license conditions; plant tour; preoperational test exception review and closecut; review of events occurring during the reporting period; monthly maintenance observation; review of periodic reports and review of plant modification Result: No violations were identifie PDR ADOCK 05000352 G PDR

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DETAILS 1.0 Persons Contacted Philadelphia Electric Company J. Basilio, Administrative Engineer J. Doering, Operations Engineer R. Dubiel, Senior Health Physics

'P. Duca, Technical Engineer J. Franz, Superintendent of Operations G. Lauderbach, Quality Assurance Engineer G. Leitch, Station Superintendent Also during this inspection period, the inspectors discussed plant status and operations with other supervisors and engineers in the PECo, Bechtel and General Electric organization .0 Followup on Outstanding Items 2.1 Violations 2. (0 pen) Violation (352/84-27-04) Pertaining to Unsealed Instrument Cable Entries In High Humidity Area The inspector observed the four instruments in the ESW pipe tunnel, and noted that only one instrument (FT-11-013A with top cable entry) was sealed. The other three instruments (FT-11-011A, B and TE-011-007A, all with bottom cable entry) were not seale The licensee's rationale for not sealing instruments with bottom cable entry was that water (due to condensation)

cannot accumulate in the instrument housing. However,the equipment manufacturer's installation instruction requires conduit sealing regardless of cable entry direction The ESW tunnel was considered a mild environment by the licensee. It is their view that there is no requirement for environmental qualifications (10 CFR 50.49) for instru-ments in this area. However, the inspector noted that the ESW tunnel was classified asahumid area where relative humidity can reach 100%. Safety related instruments in this area must be operable at 100% relative humidit In addition, even though the requirements of 10 CFR 50.49 do not appear to apply to these instruments, the requirements of 10 CFR 50 Appendices A & B do appl ~

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The licensee did not seal the instruments as specified in the manufacturer's installation instructions nor did they provide any documents to demonstrate that these safety-related instruments can function satisfactorily at 100%

relative humidity without sealing the condui This item remains open pending NRC receipt and review of information supporting qualification of the components under 100% relative humidity conditio . (Closed) Violations (352/85-06-02, 352/85-06-04, 352/85-06-05).

Inspection report 50-352/85-24 reviewed the licensee corrective actions but indicated that closure of the violations was awaiting receipt and NRC review of the Itcensee formal response. Licensee response to the viola-tions was contained in a letter dated 5/8/85 and was reviewed by the inspector. The inspector had no further question . (Closed) Violation (352/85-03-05): Inoperability of the Main Steam Isolation Valve - Leakage Control System (MSIV-LCS)

The monthly surveillance test ST-6-040-320-1, MSIV-LCS Operability Test, incorrectly left the blower and heater breakers in the open position, leaving the system out of normal alignment. The system was inoperable during the period between December 29, 1984 and January 30, 1985 while in Operational Condition 2, in violation of the Technical Specifications. The licensee revised the ST to correct the procedural error which misaligned the system. To help identify discrepant lineups, the licensee approved a routine test procedure, Control Room Tech. Spec. Check, RT-6-111-985-1, which identifies the CR indications required to meet the Technical Specifications. The inspector reviewed the revised ST and the new RT and has no further questions at this tim .1.4 (Closed) Violation (352/85-16-02): Multidisciplinary Procedure Review Not Conducted by Sub-PORC for a Surveillance Test Procedur The inspector reviewed the results of a quality assurance audit on procedures which had been reviewed by various sub-PORCs to assess the extent of instances where a multi-disciplinary review did not take place. QA audited 403 procedures in the health physics, chemistry surveillance test and fuel handling areas. Of these 403, 71 were judged p ,.i to have received an inadequate multidisciplinary review.

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In response to the audit finding, the Assistant Superin-tendent directed that the 71 procedures receive a review by the responsible system engineer from the Technical Engi-neering organization. The inspector noted the results of the system engineer's reviews which indicated that no procedures required revision to correct technical defic-iencie Further, to prevent recurrence of this violation, the Assistant Superintendent, in a 4/30/85 memorandum to all PORC members, emphasized and clarified the requirements of administrative procedure A-4 regarding the need for the sub-PORC chairman to assure mult1 disciplinary reviews of procedure In discussion with the inspector, the Assis-tant Superintendent indicated an intent to revise procedure A-4 to incorporate the guidance provided in his 4/30/85 memorandu The inspector had no further question .2 Unresolved and Follow Items 2. (Closed) Unresolved Item (352/85-03-13) pertaining to valve failure due to water accumulation and unsealed conduit connecting to environmentally qualified motor operated valve HV-56-1F059. The inspector reviewed Limerick EQ report Appendix E page 873 dated April 24, 1984, which indicated that the specified relative humidity (RH) is 90%

while the valve is qualified for 100% RH. The inspector also reviewed Finding Report No. N-466 dated February 4, 1985 and its resolution dated April 16, 1985 based on an engineering evaluation dated March 1985. The engineering evaluation indicated that for water accumulation to occur, many incidents had to occur concurrently and therefore, the probability was extremely low. The inspector agrees that repeating of this event is very unlikel The inspector reviewed the inspection record (QCIC N ) dated February 5,1985. This record indicated that the rework and testing of HV-56-IF059 valve actuator were complet The inspector also observed the reworked valve located in the HPCI compartment at 177' elevation. No deficiencies were identifie Based on the above review, this item is close .

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2. (Closed) Unresolved Item (352/84-71-02): the absence of specific plans to perform HPCI vortex. testing in accordance with FSAR Section Inspection Report 50-352/85-24 provided a preliminary review of this ite The inspector reviewed LDCN-FS-906 approved 5/16/85 and enclosed safety evaluation report approved 5/10/85, which approved changes to FSAR section 9.2.7; LDCN-FS-907 approved 5/16/85 and enclosed safety evaluation report approved 5/16/85, which approved changes to FSAR section 6.3; and ST-2-055-401, "ECCS Condensate Storage Tank (CST) Level Low (division 2) HPCI Calibration /

Functional Test", performed 11/25/84 and ST-1-055-100,

"HPCI Logic System Functional / Simulated Automatic Actuation",

performed 3/29/85. The inspector also contacted several licensee personnel. Based on review of the documents and discussions, the inspector concluded that the licensee has demonstrate 6, by a combination of test and analysis,-that vortex conditions will not occur in the CST prior to completion of the HPCI pump suction transfer from the CST to the suppression pool. The licensee evaluation of the FSAR changes did not identify an unreviewed safety questio .2.3

(Closed) Licensee-Identified Item (352/85-02-06): Fire Valves Closed After Hydro (LER 85-015).

To prevent improper system restoration following surveillance testing and/or maintenance, the licensee has revised Administrative Procedure A-41, " Procedure for Control of Plant Equipment" to include equipment that :::ay be nonsafety-related', but required i.y the Technical Specifications to be operable or in surveillance and additional instructions for independent verification of blocking permit removal. The inspector also noted that Bechtel Maintenance and Modifica-tion Procedure, BMMP-M-1, " Procedure for Pressure Testing of Piping and Components", was approved and issued to provide the craft with direction in related to their work on PECo-owned equipment, systems and facilitie This BMMP replaces a similar construction job rule (applicable to work on equipment prior to turnover to PECo), that had been inappropriately used for the hydrostatic testing of part of the fire suppression system. Other actions taken to correct the inappropriate closure of two valves on the fire suppression system were:

(a) restoration of the inoperable system to service, and

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(b) instruction to contractor supervision and craft personnel that equipment within the confines of an equipment tag-out must only_be operated by PECo operations personnel or involve specific notification and approval from operations personnel. The inspector had no further question . (Closed) Follow Item (352/85-03-01): PORC Subcommitte The licensee has revised Administrative Procedure A-4,

" Plant Operations Review Committee Procedure", to delineate the responsibilities of both the PORC and any PORC subcom-mittees in relation to the review and approval of proced-ures and programs. A-4 requires the individual who was assigned responsibility for a subcommittee activity to present the activity.results at a PORC meeting which meets Tech. Spec. quorum requirement Implementation of A-4 will be reviewed by the NRC in the future during routine inspection activities. The inspector had no further question . (Closed) Follow Item (352/85-03-04): Chemistry Surveillance Test Dat The licensee has alleviated the backlog of chemistry surveillance tests (ST) awaiting approval by the Chemistry Supervisor. Steps taken include: 1) review of the STs by the Chief Supervisor or designated alternate prior to the STs being turned over for data entry into the RMMS, and 2)

training of individuals dedicated to entering chemistry ST data into the RMMS. The licensee also has plans to train all chemists in relation to RMMS data entry. The inspector had no further question . (Closed) Follow Item (352/85-03-15): NRC Personnel Acces The licensee has taken steps to provide for more expeditious access processing of NRC personnel. YOH Security Instruc-tion SI-024, Rev. O, "NRC Personnel Access," was approved and issued to the Administration Building and TSC guard houses for security force members to read and implemen This instruction establishes guidelines for the security force to promptly complete processing of NRC personnel, and has been incorporated into YOH's training module on " access control". The licensee has also developed an abbreviated site specific training program for NRC personnel. These actions are expected to allow NRC personnel unescorted access to the plant within an hour to one-and-a-half hour The inspector had no further questions on this ite *

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2. (Closed) Follow Item (352/85-13-02): Review of maintenance performed on a pressure indicator for the post accident sample syste This item was reviewed and closed during inspection 50-352/85-21 in connection with item 50-352/84-66-0 . (Closed) Follow Item (352/85-16-04): Licensee to supple-ment LER 85-2 The inspector reviewed PEC0 letter dated 5/1/85 which provided the information necessary to more completely describe the events which occurred in connection with the 1/31/85 reactor scram. Additionally, the letter provided the corrective actions the licensee had taken to address the control rod " full-in" indication problem and the apparent excess reactor coolant system cooldown rate which occurred along with the scram. The inspector had no further question . (Closed) Follow Item (352/85-03-03): Licensee to review and revise, as necessary, the temporary procedure change (TPC) proces The inspector reviewed a memorandum, dated 5/22/85, from the Plant Manager to the senior station staff which insti-

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tuted revised management controls over the TPC proces The revised process requires all TPCs to be reviewed by a responsible individual from the group associated with the procedure to characterize each TPC as being " activity unique" or " procedure discrepancy". All procedure discrep-ancy TPCs are then required to be incorporated into a permanent procedure revision within 28 days. To assist in tracking outstanding TPCs, a list of those TPCs will be l forwarded to each senior plant staff member periodicall The inspector had no further questions. This area will be routinely followed during subsequent inspection .2.10 (Closed) Unresolved Item (352/85-03-06): Licensee to establish that the 480v motor control centers (MCCs) which contain the feeder breakers to the valves in the main steam isolation valve leakage control system (MSIV-LCS) are accessible after a LOCA.

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, The inspector reviewed a PECo engineering memorandum, dated l 3/21/85, which forwarded to the Plant Manager the results

! of a dose assessment performed by Bechtel and PECo to determine the accessibility of the MCCs associated with the

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MSIV-LCS. The results of the assessment indicated that, while the reactor had been operating at power levels less than 5 percent power during the startup test program, these MCCs would have been accessible. However, these MCCs would not be accessible after extended operations at 100 percent powe Consequently, the licensee implemented M0CP-379, which closed the feeder breakers to all MSIV-LCS valves. To accommodate the concerns which necessitated these feeder breakers being maintained initially open (i.e., concerns for exposure fires causing spurious valve actuation),

revisions were to be made to the associated fire strategy procedures to require opening of the feeder breakers under certain, specified fire scenario The inspector reviewed Fire Strategy procedures F-A-542, F-R-304, F-R-402, F-R-407 and F-R-500. Further, the inspector reviewed the MSIV-LCS system checkoff list which reflected the new valve status and toured the control ro' , and verified that all valve feeder breaker were closed as of 5/21/85. The inspector had no further question .3 Bulletins 2. (Closed) 84-BU-01: Cracks in Boiling Water Reactor Mark I Containment Vent Headers This Bulletin described a problem which occurred at Hatch, Unit 2, wherein cracks developed in the containment vent header as a result of the impingement of cold nitrogen gas on it during containment inerting. This problem, along with recommendations for corrective action, was also described in General Electric Service Information Letter (SIL) 402. The licensee provided information to NRC Region I on the actions it was taking in response to the Bulletin and the SIL in a letter dated 9/26/84. These actions included modifications to the nitrogen supply piping system within the reactor enclosure and to the liquid nitrogen storage and evaporation system outside the power bloc The modifications to the supply piping system were installed per Modification Design Change Package (MDCP) 0197 and were further described in NRC Inspection Report 50-352/85-1 During this inspection, the inspector reviewed the licensee's plans for installing the modifications to the storage and evaporation system and its plans for periodic functional testing of the nitrogen system.

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The inspector reviewed MDCP 0493, which described the modifications prepared by Union Carbide's Linde Division for implementation as the nitrogen system storage and evaporation skid. These modifications, scheduled to be implemented prior to initial containment inerting, included:

(1) Relocation of the temperature element, used to provide a closure signal to the evaporator control valves on low nitrogen temperature, from downstream of the control valves to upstream of the control valve This action was necessary because the initially installed configuration was susceptible to cold ambient temperatures (i.e., winter weather) preventing the normal opening of the control valve (2) Removal of the manual bypass line around the control valves which had been used to provide a means of heating the temperature element with warm gas in order to permit normal control valve operation during cold weather conditions. The bypass line was replaced by a line with a third control valv (3) Addition of two ambient evaporators and a topping heater to. allow for operation of the skid at low flow conditions without requiring operation of an auxiliary boile Regarding the licensee's plans for periodic testing of the system, the inspector noted that four surveillance tests were being developed as indicated below:

ST Frequency Function ST 2-057-410-0 6 month Calibration and functional

. test of the evaporator temperature control ST 2-057-411-0 6 month Calibration and functional test of the supply system's pressure and temperature control ST 2-057-412-1 12 month Calibration and functional test of the supply system's high/ low controls and indications (including testing of the auto-closure of HV-57-160A on high/ low system temperature).

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ST Frequency Function ST 2-057-600-1 6 month Functional test of high/lcw temperature switch (TSHL 57-060) for the supply syste The inspector noted that the procedures to implement the above STs were being drafted. However, the inspector observed that the STs had been placed on the licensee's ST scheduling and tracking system, indicating them to be due prior to initial containment inertin The inspector also reviewed a draft change to system procedure S57.1A which implemented requirements for monitoring nitrogen supply system temperature for the first 15 minutes of each inerting cycl In conclusion, the inspector considers the inspection of the licensee's response to the Bulletin and SIL to be complete. Modifications to the supply piping have been implemented and associated periodic testing has been identified and scheduled. Regarding the skid modifications described in MDCP 0493 but not yet implemented, the inspector views these system changes as providing for redundancy in the low temperature protection already installed and as providing for optimization of evaporator system performanc However, to verify that the licensee adheres to the commit-ments made to NRC in its 9/26/84 letter in response to IEB 84-01, NRC Region I is proposing to condition the full power license (NPF-39) to require that the modifications described in MDCP 0493, or suitable alternates, be installed prior to initial containment inertin .4 Three Mile Island (TMI) Action Plan Items 2. (Closed) TMI Item II.F.1: Accident Monitoring Instrumenta-tion, Containment Pressure, Suppression Pool Level and Containment Hydrogen Monitor The inspector reviewed sections 1.13 and 7.5 of the FSAR and section 7.5 of the Safety Evaluation Report to ascertain the actions taken regarding this requirement. Additionally, the inspector observed the installation of the control room instrumentation, reviewed the calibration procedures for these instruments and d hcussed with licensed operators the use of these instruments for implementation of the emergency operating procedure *

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The inspector determined that the following instruments were installed and were identified by a yellow tape on the indicator faceplate, as Regulatory Guide 1.97 qualified instruments:

Functions Instrument Range Contair. ment Pressure PR57-101 -5 to +165 psig PI42-101 -5 to +165 psig PI57-121 -5 to +5 psig Suppression Pool Level LI52-140A 0 - 50 f LI52-140B 0 - 50 f Containment Hydrogen AI57-151 0 - 30%

AI57-188 0 - 30 The inspector noted that, in the case of the suppression pool level instruments, the FSAR appeared to not match the field installation. The FSAR, in Table 7.5.3, identified the level instruments as having a 0 - 30 ft. range. The as-installed instruments and the surveillance tests used to calibrate them show their range to be 0 - 50 ft. The inspector did not consider this difference to be a significant safety concer The inspector determined, based on a review of Off-Normal, Operational Transients and Transient Response Implementing Procedures, that the qualified instruments are not mentioned by instrument numbe Rather, the procedures refer only to the name of the parameter, e.g., drywell pressure. The inspector determined that procedure revisions would not be necessary provided the operators recognized the significance of the yellow tape on the control room instrument However, in conversations with various senior licensed operators, the inspector noted that, although the operators were generally aware of the reasons for the yellow tape on the instruments, they had not been formally trained regarding the need to rely on these instruments during accident situations. Accordingly, after a training discussion with the inspector, the Operations Engineer issued a 5/15/85 memorandum to the' shift informing them of the significance of these instruments. Further, the Limerick Training Section was requested to include emphasis on the use of these instruments during accident scenarios in the requal-ification training progra The inspector had no further question .

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2. (Closed) TMI Item III.D.1.1 Primary Coolant Sources Outside Containment l In accordance with the Safety Evaluation Report and with Technical Specification (TS) 6.8.4, the licensee was required to establish a periodic inspection, maintenance and leak test program for various systems. The inspector verified that surveillance test procedures had been imple- mented to conduct the required inspections and tests every 18 months as indicated belo System (as identified in Surveillance Test TS 6.8.4)

Core Spray ST-1-052-701-1 ST-1-052-702-1 HPCI ST-1-055-701-1 & 702-1 RCIC ST-1-049-701-1 & 702-1 RHR ST-1-051-701-1 to 704-1 Post-Accident Sampling ST-1-030-700-1 & 701-1 ST-1-057-701-1 Safeguard Piping Fill ST-1-052-705-1 Scram Discharge Piping ST-1-047-700-1 i Containment Atmosphere Control ST-1-058-701-1 & 702-1 The inspector also verified that the required preventive maintenance'(PM) items had been identified, assigned procedure numbers, and entered in the licensee's tracking program. With the exception of the core spray system, the l PM procedures have not yet been written. These procedures are not required until the PM items are due which will be at the first refueling. The licer.see indicated that the PM tracking system will identify each PM requirement with sufficient lead time to accomplish each ite The inspector finds the licensee's program acceptabl This item is closed.

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3.0 Followup on Selected Low Power License Conditiors

.3.1 (Closed) License Condition 2.C.(5): Environmental Qualification of Primary Containment Equipmen The licensee has revised all environmental qualification files for equipment located inside the primary containment to reflect the use of the NUREG-0588 generic temperature profile or the NRR-approved qualification profile. NRR has found this course of action acceptabl (Comments are contained in the Limerick SER, Supplement No. 2, Section 3.11.3.3.1.) A regional inspector reviewed a sample of the

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Equipment Qalification Records (EQR) for the primary containment and determined that the EQRs had indeed been revised to reflect the use of NUREG-3588's generic temperature profile. The ins'pector had no further question .2 (Closed) License Condition 2.C.(6)d: Fire Protectio The inspector reviewed the following three items to this license condition:

(a) installation of automatic sprinkler systems (Preaction System Nos. 63, 64, 65 and 66) in Fire Area 41 (RECW Equipment Area)

and 42 (Safeguard System Access Area),

(b) installation of additional automatic sprinkler system (Preaction System Nos. 62 and 67) in theNortheast corner of the RB (Fire Area 47A), and (c) completion of modifications to the control structure fire protection system, to ensure flow of 100 gpm at 65 pst from the standpipe hose station The inspector reviewed the P & 10 (Drawing 8031-M-22) for items (a)

and (b) and walked down each line to verify installation had been completed. The inspector had no questions, and considers items (a)

and (b) close The inspector also reviewed the calculations for item (c) to determine whether the required flow of 100 gpm at 65 psi was achieved at the two additional hose reels. The inspector concluced that this minimum ficw and pressure had indeed been achieved. This item is considered close .3 (Closed) License Condition 2.C.(14)a: Interim measures for a redundant remote shutdewn capability using existing procedures and equipmen The licensee was required to develop procedures to be used to effect a redundant, single-failure proof means of remotely achieving hot and cold shutdown conditions. This redundant method was intended to be available in the event the control room would become uninhabitable and controls did not function from the remote shutdown panel. The design bases events for the shutdown approach encompassed accidents and expected operational occurrences, but did not involve Appendix R fire consideration _

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The inspector reviewed procedure SE-6 " Alternate Remote Shutdown",

and determined that it provided the redundant method described in the licensee's letters dated March 25, April 18, and April 25, 198 Additionally, the inspector reviewed the maintenance request forms described below and verified that they had replaced the associated remote shutdown panel indicators with qualified and calibrated components as committed to by the licensee in its April 18, 1985 letter:

MRF Instrument Function 8503767 FI49-1R001-1 RCIC flow 8503764 PI42-1R011 RPV pressure 8503766 LI42-1R010 RPV water level 8503763 FI51-IR005 RHR loop A flow The inspector had no fu'rther question .4 (Closed) License Condition 2.C.(2): Deferred Item The inspector reviewed Attachment I to NPF-27 to determine the status of the various conditions contained in the appendi The inspector determined that all preoperational tests had been completed and those preoperational test exceptions required to be resolved prior to exceeding 5 percent power had in fact been resolved. The inspector also verified that items 4a through d of Appendix 1 had been resolved prior to initial criticality as required by NPF-27. Further, the inspector verified that items 5a and 6a had been completed. Documen-tation of the closure of these items has been included in this and other NRC inspection report No violations were identifie .0 Plant Tour

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4.1 Unit 1 Periodically during the inspection period, the inspectors toured the Unit 1 containment, the reactor enclosure, the control enclosure, the turbine enclosure, the diesel generator enclosures, the radwaste enclosure, the off gas enclosure, and the site perimeter outside the power block. The inspectors examined preventive and corrective maintenance, surveillance testing, tagging of equipment, housekeeping, radiological control practi:es, portal monitoring, security, lighting, vehicular control, power block control points, security fencing, fire protection equipment, environmental controls, and general plant operations. The inspectors routinely toured the control room to verify proper control room manning, procedural compliance, safety

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system availability, and nuclear instrumentation operabilit Operating logs, the jumper-bypass log, the temporary circuit altera-tion (TCA) log, operating orders _and plant trouble reports were reviewed to _ verify that all technical specification requirements were met. Interviews and discussions were rutinely conducted with licensee operators and staff concerning the status of off-normal alarms, ,

compliance with technical specifications and general plant condition No violations were identifie .2 Unit 2 The inspector routinely observed activities in the areas of the facility common to both Unit 1 and Unit No discrepancies were note .0 Preoperational Test Exception Review and Closeout

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The inspector reviewed the licensee's dispositions of the following -

preoperational test exceptions (TEs) to assesstheir technical adequacy

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and to verify that these exceptions had been suitably resolved. These TEs had been prioritized as being required to be resolved prior to exceeding 5 percent reactor power.

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Test Test Exception Number IP72.1 Gaseous Radwaste 28 System IP76.2 Post Accident 6 Sampling System No violations were identifie .0 Review of Events Occurring During the Reporting Period Inadvertent Diesel Generator Startup on May 6, 1985 On 5/6/85, the D13 diesel generator inadvertently started as a result of a troubleshooting activity being performed by a station power generation engineer. To investigate the possibility that vibrations l caused by closure of 4 KV switchgear breakers could cause spurious actuation of 4KV relay targets, the engineer rapped on the door of

, the 013 output breaker cubicle. An auxiliary relay, an Agastat EGPD series component, picked up, which resulted in the closure of the 013 '

output breaker onto the already energized D13 4KV bus. The generator ,

end of the diesel generator was motorized, causing the diesel shaft

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to spin. The D13 output breaker tripped open on reverse power, but not before diesel speed had exceeded 200 rpm. Once above 200 rpm, '

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the fuel system logic admitted fuel to the engine, starting the D13 diesel. The diesel generator operated at rated speed with its generator at rated no-load voltage and frequency. Operators diagnosed the problem and secured the engine from the control room. The D13 diesel generator was placed in an inoperable status while the generator was evaluated. Further tests on the generator and the diesel indicated that no adverse consequences resulted from this even The inspector discussed this event with representatives of station management on 5/8/85 and 5/10/85 to determine the corrective actions to be taken and to assess the implications of this event on the seismic qualifications of the switchgear. Additionally, the inspector reviewed Upset Report 1/85/011 regarding this even The inspector learned that no adverse consequences should be expected as a result of motorizing the EDG. According to the vendor manual from Fairbanks-Morse, motorization of the generator is an acceptable method for checking proper phasing of the generator. Further, based on a review of the generator breaker logic diagram (Dwg. E-164 Sh. I and 2), the inspector determined that motorization of the generater and the resultant reverse power trip of the output breaker would not adversely affect the ability of the EDG to automatically pick up the associated 4160 V bus if required. As had occurred on 5/6/85, the EDG would be expected to be operating at rated no-load conditions,

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ready to close into the 4160 V bus if necessar To determine if the cause of this event, i.e., banging on the switch-gear cubicle door, implied that the seismic qualification of the switchgear was in question, the inspector discussed this matter with a representative of the PEco electrical engineering organization on 5/10/85. The inspector was informed that the switchgear vendor, Brown Boveri, had qualified the switchgear per IEEE-344 by testing a prototype component. The prototype had been configured with working relays and components which were tested to verify that acceptable operations would be possible during and after a safe-shutdown (SSE)

or operating basis (OBE) earthquake. Included in these tests were checks of relay operations for contact chatter. Further, during the tests accelerometers had been installed at various locations within the switchgear cubicles to determine acceleration amplification factors. These factors could then be applied to the floor response spectra to which the cubicles were qualified, to establish required qualification levels for components added to the prototype to meet field needs. Accordingly, the qualifications necessary for the Agastat EGPD relays in each of the EDG output breaker cubicles were determined to be 4 g's vertical; 3 g's horizontal. The inspector was informed that the Agastat EDPD relays were qualified to 4 g's hort-zontal and vertica .

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, The licensee indicated that the event of 5/6/85 did not, therefore, b indicate a problem with the seismic qualifications of the switchgea ' Apparently, the shock imparted by the power generation engineer to the relay in the 013 cubicle was dissimilar to the forces applied to the relay during an SSE or OB Regarding corrective actions for this event, the licensee informed the inspector that signs would be attached to the switchgear warning against disturbing the cubicle door. Further, the licensee's engineering organization is considering a modification to move the Agastat relays off the cubicle doo No violations were identifie .2 Inoperable Fire System Detectors and Sprinklers Noted May 17, 1985 On 5/17/85 at about 12:10 a.m., while performing surveillance test ST 2-022-613-1, an instrument and control technician found that the alarm relay in the fire suppression system release control panel for the B diesel. generator room had been made inoperable by someone inserting tape between the relays contacts. As a result, the heat detectors in the B diesel generator room were incapable of causing either a coded alarm for the room or of automatically initiating the sprinkler system in the room. Inoperability of these fire detectors and of the sprinkler system violated the requirements of Technical Specifications 3.3.7.9 and 3.7. The inspector was made aware of the above prcblem during.a review of control room logs later on 5/17/85. Subsequently, the inspector discussed the event with licensee representatives on 5/17 and 5/20/8 Based on these discussions, the inspector learned that, while the tape on the alarm relay contacts had adversely affected the design function of the heat detectors, it did not impair the ability of the installed smoke and infrared detectors to annunciate an early warning alarm, nor did it prevent manual actuation of the sprinkler syste The licensee further informed the inspector of the results of its investigations into this matter and of its corrective actions. The licensee indicated that ST 2-022-613-1 had last been successfully performed on 11/9/8 Subsequent to that date, a maintenance activity was performed in the release control panel around 3/1/85. Although work on the alarm relay was not included in the scope of work, the individual who performed the work indicated that he did not observe tape on the contacts. As a result, the licensee concluded that the taping of the contacts probably occurred during the period 3/1 -

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For corrective actions, the licensee indicated that all 20 release control panels similar to the one involved in this problem were

~ inspected'and found to be satisfactory. The licensee's corporate and site security organizations were informed; representatives of the site organization in company with the Regulatory Engineer inspected the area in the diesel generator enclosure and the service water pipe tunnel and found no problems. 'The system checkoff lists for the 4 diesel generators and for the fire protection system were completed without problem. However, in the area of key control, the inspector was informed by the licensee that there were no strict key issuance controls in place for the release control panels. As a result, the licensee affixed seals for the 20 panels involved by 5/21/85, and commenced a daily inspection of these tamper seals. The daily inspection requirement is intended to be in place until a permanent key control method is implemented for fire protection panel The inspector had no further questions. Also, because 2 of the 3 modes of fire detection and warming remained operable, because manual suppression system operation remained available and because the licensee's fire brigade's past performance indicate that a fire in the B diesel generator room while the alarm relay was inoperable would reasonably have been suppressed using manual methods, the inspector did not judge the violation of technical specifications to be a significant safety problem. Consequently, based on the pro-visions of 10 CFR 2, Appendix C regarding self identification and correction of problems, the inspector considered this event to be a Licensee Identified Ite .0 Monthly Maintenance Observation The inspector periodically reviewed the status of selected maintenance activities to verify compliance with the station's administrative procedures and to assess the technical adequacy of the repair technique. During this month, work under Maintenance Request Form 8504596 on the diesel-drived fire pump was observe .

No violations were identifie .0 Review of Periodic Reports The inspector reviewed, for accuracy and detail, the licensee's monthly operating report for April 198 No violations were identifie _

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9.0 Review of Plant Modifications The inspector reviewed documentation associated with the following plant modifications:

Modification Number Subject 84-0207 Recirc. Loop pipe hanger load adjustments84-184 Addition of loss of voltage relays for the-20 VDC output from SRM/IRM power supplies85-171 Installation of " Instrument Head Chambers" for essential reactor vessel water level measurement instrument Security Equipment Replacement 85-170 Installation of larger dowell pins in HPCI pump turbine pedesta Specific items reviewed were: (1) the conduct and adequacy of safety evaluations accomplished (pursuant to 10 CFR 50.59), (2) post implementa-tion testing, (3) technical adequacy, (4) quality assurance group involve-ment, (5) updates of plant drawings, (6) proper screening of modifications by the Plant- Operations Review Committee (PORC), (7) controls to assure appropriate changes are made to other affected plant documents, (8)

controls to assure necessary training is conducted, and (9) protection of security information associated with a security system modificatio A modifications group representative informed the inspector that the PORC is requiring improvements in safety evaluations. No longer are marginally adequate evaluations accepted. (One marginally adequate evaluation was noted by the inspector for modification 84-0207.) PORC recognition of problems in this area and emphasis on improvement is a positive tren One poor practice was identified in the area of acceptance test reviews for modifications84-184 and 85-171. In both cases the same individual that performed the test (and signed the operation verification test '

document as the performer) also acted and signed as the test reviewe Governing procedure A-14, " Procedure For Control of Plant Modifications",

Revision 2 dated October 24, 1984, does not give specific guidance in

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this area; however, involvement of a second individual to verify that

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test results are acceptable would seem prudent. The inspector discussed the concern with the Technical Engineer. The Technical Engineer agreed that conduct of test reviews by a second individual would be a better practic No violations were identifie .a

10.0 Exit Meeting-The NRC resident inspector discussed the issues and findings in this report throughout the inspection period and at an exit meeting held with Messrs. J. Corcoran and G. - Leitch on May 31, 1985. At this meeting the representatives of the licensee indicated that the items discussed in this report did not involve proprietary information. No written material was provided to the licensee during this perio ,

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