IR 05000352/1985038

Insp Rept 50-352/85-38 on 850930-1106.No Violation Noted. Major Areas Inspected:Startup Test Program During Test Condition TC-3,including Startup Test Witnessing,Test Procedure Review & Qa/Qc Interfaces

ML20137Z607
Person / Time
Site:	Limerick
Issue date:	11/27/1985
From:	Eselgroth P, Florek D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20137Z581	List: IR 05000352/1985038 ML20137Z578
References
50-352-85-38, NUDOCS 8512110351
Download: ML20137Z607 (14)

Text

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-38 Docket N License No. NPF-39 Priority -

Category C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 racility Name: Limerick Nuclear Generating Station Inspection At: Limerick, Pennsylvania Inspection Conducted: September 30, 1985 - November 6, 1985 Inspector: h 0. Floreli, d Reactor Engineer

1. - 2 7- 6 date Approved by: #-27-Tr f P. E'selgroth,fitef, Test Program Section date Inspection Summary: Inspection on September 30, 1985 - November 6, 1985 (Inspection Report No. 50-352/85-38)

Areas Inspected: Routine unanounced inspection of the startup test program during test condition TC-3 including startup test witnessing, test procedure review, test results evaluation, overall startup program and plateau review; review of startup report;-QA/QC interfaces; independent measurements; and tours of_the facilit The inspection involved 81 hours9.375e-4 days <br />0.0225 hours <br />1.339286e-4 weeks <br />3.08205e-5 months <br /> onsite by one region based inspecto Results: No violations were identifie NOTE: For acronyms not defined refer to NUREG-0544 " Handbook of Acronyms and Initialisms" 0512110351 851206 PDR ADOCK 05000352 G PDR

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P 1.0 Persons Contacted Philadelphia Electric Company (PECo) and Contractors J. Armstrong, Assistant Operations Engineer

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D. Atkinson, Lead Startup Test Coordinator

• C.'Endriss, Regulatory Engineer P. Fleckser, Startup Test Scheduler

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, J. Franz, Superintendent of Operations M. Held QC Engineer

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• J. Isaacs, NSSS Test Supervisor A. Jenkins, Startup Test Program Supervisor i *G. Leitch, Plant Manager

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, J. McElwain, QA Auditor

• J. Rupert, QA Site Supervisor

• R. Smith, QA Auditor i * Warren, Test Engineer

. U.S. Nuclear Regulatory Commission E. Kelly, Senior Resident Inspector i

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• Denotes those present at the exit interview on November 6, 1985.

The inspector also contacted other licensee and contractor personnel in the course of the inspection including reactor operators, startup test engineers and technical staf .0 Startup Program l

References

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Regulatory Guide 1.68, Revision 2, " Initial Test Program for Water-Cooled Nuclear Power Reactors" i *

ANSI 18.7 - 1976, " Administrative Controls and Quality Assurance for 4 the Operational Phase of Nuclear Power Plants"

Limerick Generating Station (LGS) Technical Specification

• LGS Final Safety Analysis Report LGS Safety Evaluation Report i

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Specification NEB 0 23A1918, Revision 0, " Limerick 1 and 2 Startup Test Specification"

! * LGS Startup Program Schedule

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Administrative Procedure A-200, "Startup Test Procedure Format and Content"

Administrative Procedure A-201, "Startup Test Procedure Control" i

Administrative Procedure A-202, "Startup Test Implementation"

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Administrative Procedure A-203, "Startup Test Program Personnel Training and Qualification" 2.1 Test Witnessing Scope The inspector witnessed portions of the preparation, conduct and recovery of the following startup and hot functional tests.

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HF-33 " Recirculation Pump Flow Control Tuneup" STP-22.1 " Pressure Regulator Response - Control Valve Operation" i

STP-15.5 "High Pressure Coolant Injection (HPCI) Cold Quick Start

, Injection to the Reactor Vessel" A

j The tests were witnessed for the attributes identified in Inspection Report 50-352/84-74 in section 2.2.

i Discussion

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During performance of HF-33, the inspector witnessed the performance of a speed change in the A recirculation pump from 62% - 58%.

, Changes in pump speed were performed from the auxiliary equipment

{ room under the direction of the reactor operato ; On October 24, 1985 the inspector witnessed portions of the per-l formance of STP-22.1. The inspector witnessed the briefing of the

operations personnel by the test director. The briefing was compre-

. hensive and thorough with many questions being asked by the operators

to assure safe conduct of the test. The inspector witnessed the

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performance of the failed regulator test which failed the A regulator and allowed the B regulator to assume control. A 10 psid negative step of the B regulator was also observed. Plant response was noted '

to be as expected for conduct of these test On November 5, 1985 the inspector witnessed preparation and conduct

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of STP-15.5. This test was a cold quick start of HPCT injecting into the reactor pressure vessel. The reactor was at 65% power for this

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J tes Prior to conduct of the test, the inspector observed a compre-hensive and thorough test briefing conducted by test personnel with

, operations personnel.

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At approximately 1105 a.m. HPCI was manually initiated for vessel injectio HPCI achieved rated flow into the reactor vessel in 31 seconds. This time exceeded the test level acceptance criteria of less than or equal to 25 seconds and also exceeded the technical specification requirement of less than 30 seconds. The inspector 1 observed feedwater response to the HPCI injection flow (approximately 30% of total feedwater flow). Initial reactor water level was 31 inches and peaked at 40 inches._ Feedwater response appeared accep-table. -The licensee then attempted step changes in flow in both manual and automatic control. Stable response was observed in manuals however when the controller was in automatic, steady oscillations in HPCI turbine speed were observed and flow steps were not attempte 'The licensee was monitoring suppression pool temperature during these activities and HPCI was manually tripped at 1211 p.m. due to suppression pool temperatures approaching 105 F.

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Because of the time response failure, the licensee declared HPCI inoperable and placed a hold on plant power increases and limited the type of testing that could be performed. This was in accordance with the administrative procedures for startup testin The inspector witnessed portions of licensee post testing acti-vities to resolve the HPCI time response failures. Multi discipline

, as well as GE San Jose personnel were utilized to determine the adjustments and repairs necessary to resolve the problem. The

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licensee plans to decrease the time of the ramp generator and to I retune the controller to eliminate the oscillations.

I The licensee planned to perform a retest after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> had elapsed since the HPCI auxiliary oil pump was operated. This is compatible '

with technical specifications for an inoperative HPCI. The delay permits minimizing feedwater and core spray nozzle cycles when the

HPCI is operating. HPCI testing was also observed by the Senior

. Resident Inspector. Licensee resolution to the test failure will be reviewed in a subsequent inspectio F'.1 dings

No violations were identifie . _ _ _ _ _ _ _ _ - _ - _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ - - _ .

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2.2 Startup Test Procedure Review Scope The procedures listed below were rev'iewed for technical and administrative adequacy. The attributes contained in Inspection Report No. 50-352/84-50 Section 2.2 were utilize STP-36.0 " Piping Dynamic Transients," Revision 1, dated November 28, 1984 STP-36.3 " Recirculation Piping Vibration During Selected Transients," Revision 0, dated July 12, 1984 STP-36.5 "Feedwater Piping Vibration During Reactor Feed Pump Trip," Revision 1, dated November 28, 198 ,

Findings No violations were note .3 Test Results Evaluation Scope

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The startup tests listed in the discussion section below were reviewed for the attributes identified in inspection report 50-352/84-70, Section 3.3. In addition,.the inspector reviewed 34 test exception reports that have been closed out by the licensee and 34 test exception reports that have not completed all the steps for final closeout for technical adequacy and processing in accordance with the administrative procedure Discussion Except as noted below, all startup test results were found to meet the attributes referenced above. A summary of each startup test follows. The test exceptions reviewed were all found to be acceptabl . The tests listed below were those tests performed in test condition 2 and have been reviewed and accepted by licensee managemen STP-1.2 " Chemistry Data", Revision 0, Test implemented August 29, 1985 I

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This test was performed with the reactor at 28% powe Reactor water chemistry satisfied the acceptance criteria as follow Value Limit Conductivity micromho/cm .66 s Chloride ppb s 200 pH .6 s pH s Test exceptions identified were processed in accordance with the administrative procedure STP-2.1, " Radiation Surveys", Revision 1, Test implemented August 23, 198 All acceptance criteria were satisfie STP-5.8, " Scram Timing of Selected Rods During Planned Scrams",

Revision 1, Test implemented September 12, 198 The selected rods were 10-39, 26-39, 30-35 and 38-27. The scram times to notch 05 ranged from 2.59 to 2.77 seconds with an acceptance criteria of less than 3.49 second STP-9.1 " Reference Leg Temperature Comparison," Revision 1, Test implamented August 28, 198 Acceptance criteria were satisfie STP-12.3 "High Power APRM Calibration", Revision 1, Test implemented August 28, 1925 All acceptance criteria were satisfied. APRM settings were as follows:

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ApRM DESIRED LEFT A 4 .0 B 4 .0 C 4 .0 0 4 .4 E 4 .0 F 4 .2 The as left values were corrected for fraction of rated power (FRTP) exceeding core minimum fraction of limiting power density CMFLP ]

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STP-13.4 " Dynamic System Test Case", Revision 1, test implemented August 23, 198 Test exceptions identified were processed in accordance with the administrative procedures. The startup test veri-fied the P-1 operation of the process compute STP-13.8 " Acceptance Criteria Verification", Revision 1, Test implemented August 27, 198 Backup computer program BUCLE and the process computer cal-culated the same positions and values for MFLPD, MAPLHGR and MFLCPR and thus satisfied the test acceptance criteri STP-19.2, " Process Computer Calculation", Revision 1, Test implemented August 28, 1985 Reactor Parameters satisfied acceptance criteria Power 38.7%

MFLCPR .556 MFLPD .475 MAPRAT .466 STP-22.1 " Pressure Regulator Response-Control Valve Operation,"

Revision 1, Test implemented September 6, 198 All testing was completed. Transient variables to i 10 psi step changes in pressure regulator and failed regulator steps did not diverge. Test exceptions identified were processed in accordance with the administrative procedure STP-22.3 Pressure Regulator Response - Bypass Valve Operation",

Revision 1, Test implemented September 6, 198 Transient variables to 110. psi step changes in pressure regulator and failed regulator steps did not diverg Test exceptions identified were processed in accordance with the administrative procedure STP 23.2 "Feedwater System Manual Flow Step - B Pump", Revision 0, Test implemented September 3, 198 During the step changes no divergent oscillations were noted. Test exceptions were identified for not obtaining all the data required by the procedure; however, sufficient data was obtained to perform the analysis steps. Test exceptions were properly identified and processe __

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STP-23.2 "Feedwater System Manual Flow Step - A Pump", Revision 0, Test implemented September 14, 198 See response for feedwater pump #

STP-23.2 "Feedwater System Manual Flow Step - C Pump", Revision 0, Test implemented September 1, 198 See response for feedwater pump B STP-23.3 "Feedwater System Level Setpoint" Revision 0, Test implemented September 4, 198 inch steps were made in both single and three element control with the B and C feedwater pump operatin No divergent oscillations were observed. However oscillations noted exceeded the level 2 acceptance criteria. The test exception was processed in accordance with the administra-tive procedur STP-26.2 " Relief Valve Rated Pressure Test", Revision 2, Test implemented September 6, 198 Average change in generator output was 40.9 MW(e) when the 14 safety / relief valves were operated. The range of values was 38.5 to 43.8 MW(e). The level 1 acceptance criteria were satisfied. Test exceptions identified were processed in accordance with the administrative procedure STP-27.1 " Turbine Trip Within Bypass," Revision 0, Test implemented September 6, 198 With reactor power at 22.2% a turbine trip was initiate When plant parameters stabilized, of the 9 turbine bypass valves, 6 were full open and one was 45% open and reactor power stabilized at 21.9%. The reactor did not tri Acceptance criteria were satisfie STP-28.1 " Reactor Shutdown to Hot Standby" Revision 1, Test implemented September 12, 198 Shutdown f rom outside the control room was demonstrated and controlled. See' inspection report 50-352/85-37 for test witnessing description-STP-28.2 " Reactor Cooldown Persnstration", Revision 1, Test implemented September 11, 198 All acceptance criteria were satisfied. See inspection report 50-352/85-37 for test witnessing descriptio .

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i STP-30.3 " Recirculation System Performance", Revision 1 Test implemented August 29, 198 f All acceptance criteria were satisfie STP-31.1 " Loss of Turbine Generator and Offsite Power", Revision 1, Test implemented September 16, 1985.

, The Reactor was initially at 20.8% power. Using the sequence of events log and computer outputs the turbine trip occurred at 1751 hrs. 10 second Diesel generator breakers closed on the bus at 1751 hrs 18 seconds and at

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1752 hrs I second the reactor scram occurred on low leve HPCI initiation occurred at 1814 hours0.021 days <br />0.504 hours <br />0.003 weeks <br />6.90227e-4 months <br /> 22 seconds and MSIV

, closure occurred at 1816 hours0.021 days <br />0.504 hours <br />0.003 weeks <br />6.90988e-4 months <br /> 24 seconds. All safety

< systems functioned without manual assistanc Two minor l test exceptions were noted and processed in accordance with the administrative procedure.

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STP-32.3 " Control Enclosure Temperature and Relative Humidity",

Revision 2, Test implemented August 25, 198 ,

! Management reviewed and accepted test result STP-32.5 " Reactor Enclosure and Main Steam Tunnel Temperature",

Revision 2, Test implemented August 11, 1985.

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Management reviewed and accepted test result STP-33.1 " Main Steam Piping (Inside Drywell) Steady State

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Vibration", Revision 0, Test implemented August 23, 198 All vibration data were acceptable and satisfied the test

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STP-33.2 " Recirculation Piping Steady State Vibration", Revision 0, Test implemented August 29, 198 All vibration data were acceptable and satisfied the test criteri STP-33.3 " Main Steam (Outside Drywell) Main Steam Bypass and Feedwater Piping Steady State Vibration", Revision 1, Test implemented August 27, 1985.

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A test exception was initially identified and subsequently determined to satisfy the test' criteri ,

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STP-36.1"M$inSteamPipingVibrationDuringMainTurbineStopValve and Control Valve Closures", Revision 3, Test implemented September 6, 1985.

L Vibration data satisfied the test acceptance criteri '

STP-36.2 " Main Steam and Safety Relief Valve Discharge Piping Vibration During SRV Operation," Revision 2, test imple-mented September 6, 198 Vibration data satisfied the test acceptance criteri . The following tests were conducted in test condition TC-3 and have been reviewed and accepted by plant management,

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STP- " Radiation Butidup on Piping", Revision 0, Test implemented

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40ctober 11, 198 All data were obtained. No acceptance criteria were re-quired to_be verified in this tes STP- " Scram Timing of Selected Rods During the Turbine Trip"

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The scram. initiation signal did not print out on the chart recorder thus scram times could not be calculated. A re-

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test will be performed at the next scheduled scra *

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STP-9.1, " Reference Leg Temperature Comparison", Revision 1, Test t implemented September 29, 198 All test data were obtained and was acceptabl +

STP-12.3 "High Power APRM Calibration", Revision 1, Test implemented

September 29, 198 't

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All acce'ptance criteria were satisfied. APRM's were adjust-ed;to read equal touor greater than actual as follow *

i Desired Actual A 60.12 61 B* 59.04 6 .

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C' 61.71 62 ,

D 60.12 61 E 59.22 61 s F 59.59 60

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STP-13.5 " Program Testing at Test Condition Two", Revision 1, Test implemented October 4, 198 This test was actually performed in TC-3 after having been evaluated via the administrative procedure as not being able to be performed during TC-2. The test data were suc-cessfully obtaine STP-24.1 "Stop Valve Testing", Revision 0, Test implemented October 7, 198 Test was performed at 48% power. Margins to scram for stop valve testing were established at this power level as 62%

for neutron flux 102.5 psi for pressure and 86% for steam flow. This test will be repeated later to determine the maximum power to perform this test and not cause a reactor

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The following test results are currently in the review cycle and were reviewed by the inspector prior to manage-ment acceptance of the test result STP-19.2 " Process Computer Calculation", Revision 1, Test imple-mented September 29, 198 With reactor power at 64% power the following thermal limits were verified and were acceptable.

CMFCP = .534 CMFLPP = .567 CMAPR = .547 i STP-13.8 " Acceptance Criteria Verification", Revision 2, Test implemented October 5, 1985.

This test compared process computer thermal limits with the backup computer (BUCLE) value Thermal limit Location Process Computer BUCLE

MFLPD 31-16-11 .457 .457 MAPRAT 9-16-6 .450 .449 MFLCPR 27-16 .420 420 Acceptance criteria for these values were satisfied. Dur-ing inspector review, the inspector noted that the indepen-dent review of this startup test was conducted by an indivi-E dual who had completed a few of the procedure steps and I

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thus was not truly independent. This was brought to the attention of the licensee and another independent review was completed. Based on discussions with the licensee, the inspector concluded that this was an isolated case and the licensee is very aware of assuring people who do the inde-pendent review are truly independen STP-24.2 " Control Valve Testing" Revision 0, Test implemented October 7, 198 Test was performed at 48% power. Margins to scram for control val"e testing were determined at this power level as 62% for neutron flux, 98 psi for pressure and 87% for steamflo .4 Overall Startup Test Program The inspector reviewed the training and qualifications of six new startup test personnel to verify that they satisfied the requirements of ANSI-3.1-1981 in regards to education, working experience and the licensee administrative procedures. The records reviewed indicated that all requirements were satisfie The inspector reviewed the licensee's activities to followup observa-tions made during performance of the startup tests STP-28 " Shutdown i from Outside the Control Room" and STP-31 " Loss of Offsite Power". '

The inspector reviewed licensee operational procedures SE-1 " Remote Shutdown", Revision 6, dated September 25, 1985 and E-10/20 " Loss of Offsite Power," Revision 4, dated October 10, 1985. These procedure revisions reflected lessons learned. The licensee has additional in-process activities to complete and are being tracked by licensee operations personnel. These will be reviewed by the inspector in a subsequent inspectio The inspector held several discussions with the startup test program supervisor regarding the licensee's startup test reduction activitie The inspector reviewed the safety evaluation which combines the re-circulation pump runback test in TC-3 with a feedwater pump trip at TC-6 and safety evaluation which eliminated the Reactor Water No Cleanup Test in.TC- Both safety evaluations were found to be ac-ceptable. The licensee had also prepared a safety evaluation to delete STP-25.2 " Full Closure of Fastest MSIV" in TC-3 but decided to conduct the test anyway to obtain the dat The inspector also re-viewed a draft safety evaluation to delete the two recirculation pump trip at TC-3. Data were obtained during the turbine trip at TC-3 to satisfy the test criteria. However the licensee also decided to conduct this test to obtain additional data and provide training experience for the plant operator _

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i 2.5 Plateau Review The inspector witnessed portions of licensee PORC Meeting 85-107 on November 5, 1985 to ascertain whether the licensee is performing an

adequate evaluation of test results, to evaluate the adequacy of the licensee administrative practices in maintaining proper test dis-cipline concerning test execution, test alteration and test records and to ascertain whether the licensee is following their procedures for review, evaluation and acceptance of test result Discussion The PORC meeting reviewed startup test results and startup test ex-i ceptions. The licensee evaluation was comprehensive and thoroug The licensee was observed to follow the administrative procedures for implementation of the startup test progra Findings No violations were identifie .0 Review of Startup Report i The inspector reviewed the licensee report " Report of Initial Plant Startup

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December, 1984" Revision 0, dated September 1985, to verify that the report included the information required by technical specifications, test results reported are consistent with requirements, and corrective action is ade-quate for identified problems. No unacceptable conditions were note .0 QA/QC Interfaces

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The licensee continues to maintain a high degree of QA/QC involvement in the startup program. The inspector routinely observed QC conducting sur-veillances of startup tests. The inspector reviewed six QC surveillances reports and no unacceptable conditions were noted. QC review of completed startup. test results is also being performed in a timely manner per the administrative procedures. QA personnel are also conducting continuing audits of overall startup program implementation. The audit intervals are keyed to the test conditions. The inspector routinely observed QA audit personnel witnessing conduct of startup tests, reviewing licensee actions in the review process and providing prompt feedback to startup personnel if any inconsistencies are observed. No unacceptable conditions were note .0 Independent Measurements, Calculations and Verifications

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During the course of this inspection the inspector independently verified on a sampling basis, the prerequisites contained in the startup tests witnessed and monitored test specific parameters for adequate respons The inspector also independently verified several of the analysis steps in completed test procedures using the data collected during the test as part of the test results evaluatio .0 Plant Tours The inspector made several tours of the facility during the course of the inspection including the reactor building, turbine building, control struc-ture and control roo No unacceptable conditions were note .0 Exit Interview An exit meeting was held on November 6, 1985 to discuss the inspection findings as detailed in this report (see paragraph one for attendees). At no time during the inspection did the inspector provide written inspection findings to the licensee. At the exit, the licensee did not identify any proprietary material that was contained within the scope of the inspectio I

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