IR 05000353/1988025

Insp Rept 50-353/88-25 on 8880912-1016.Violations Noted. Major Areas Inspected:Work Activities,Procedures,Records Re Spent Fuel Pool Racks,Preoperational Test Procedure Review, Startup Test Activities,Engineering & Deficiency Repts

ML20206C892
Person / Time
Site:	Limerick
Issue date:	10/28/1988
From:	Linville J, Williams J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206C877	List: IR 05000353/1988025 ML20206C875 ML20206C883
References
TASK-1.C.1, TASK-1.C.5, TASK-2.D.3, TASK-2.E.4.2, TASK-2.K.1, TASK-2.K.3.13, TASK-2.K.3.18, TASK-2.K.3.24, TASK-TM 50-353-88-25, IEB-76-04, IEB-76-4, IEB-88-005, IEB-88-5, IEC-80-25, NUDOCS 8811160450
Download: ML20206C892 (22)

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U. S. NUCLEAR REGULATORY. COMMISSION i REGION I L 2 t

Report No. 88-25 I Docket No. 50-353 i i

License No. CPPR-107 Category A/B Licensee: Philadelphia Electric Company  !

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2301 Market Street  !

Philadelphia, PA 19101

Facility Name: Limerick Generating Station, Unit 2 Inspection Conducted: September 12, 1988 to October 16, 1988 ,

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Inspectors: R. A. Gramm, Senior Resident Inspector, Unit 2  !

R. L. Fuhrmeister, Resident 7.ispector, Unit 2  !

r E. H. Gray, Senici Reactor .ngineer, ORS  ;

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Reviewed by: u M F2/

. Wm fims, Project Engineer

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, 9/ctor Projects Sectioi 2A l Approved by: 4 /4 [

j s' C. Linvil e. Chief AT - ate !

tor Projects Section A'

Inspection Summary: Report for Inspection Conducted September 12, 1988 to !

, October )f, 1988 (Report No. 50-353/88-25)

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Areas Inspected: '

Routine inspection by the resident inspector of work activities, procedures, and records relative to spent fuel pool racks, I preoperational test procedure review, startup test activities, engineering, f; independent design and construction assessment, reactor vessel internals, and deffetency reports. The inspectors reviewed licensee action on previously l identified items and performed plant inspection tours. The inspection i involved 231 hours0.00267 days <br />0.0642 hours <br />3.819444e-4 weeks <br />8.78955e-5 months <br /> by the inspector l

Results: One violation was identified involving the fatture of GE engineering l

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to incorporate a wiring design change into the Unit 2 RRCS for the function of j i a feedwater runback as described in section The change had been originally t issued for Unit I while construction activity had ceased on Unit 2. While the t

engineering review at Unit 2 construction restart identified the necessity to !

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implement the wiring design change for Unit 2, it was never incorporated into i

! the appropriate design document or plant hardwar I

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$DR ADOCK 05000353 N

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TABLE OF CONTENTS Page 1.0 Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2.0 Plant Inspection Tours. . . . . . . . . . . . . . . . . . . . . . 2 3.0 Licensee Action on Previously Identified Items. . . . . . . . . . 4 4.0 Licensee Action on Bulletins and Circulars. . . . . . . . . . . . 5 5.0 Three Mile Island Action Plan Items . . . . . . . . . . . . . . . 6 6.0 Spent Fuel Pool Racks . , . . . . . . . . . . . . . . . . . . . . 10 7.0 Preoperational Test Procedure Revie .............. 11 8.0 Startup Test Activities . . . . . . . . . . . . . . . . . . . . . 12 9.0 Engineering . ......................... 14 10.0 Independent Design and Construction Assessmen ......... 15 11.0 Reactor Vessel Internals. . . . . . . . . . . . . . . . . . . . . 16 12.0 Deficiency Reports. . ..................... 16 13.0 Assurance of Quality. . . . . . . . ............... 18 14.0 Meetings with Licensee. . . . . . . . . . . . . . . . . . . . . . 18 Appendix 1 - Acronyms and Abbreviations

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. DETAILS 1.0 Sunmary A concern identified by the NRR design review effort involving potential misoperation of the RHR pump motors was reviewed and found to not be an operability concern (section 2). Eighteen NRC open items were reviewed and 11 were closed. As a result of inconsistencies between FSAR commitments and corrective actions presented for the open items several remain open (sections 3, 4 and 5). The spent fuel pool rack insta'lations were found properly controlled (section 6). Review of the RRCS design documents identified a wiring error in the feedwater pump runback circuitry. A GE design change had been implemented for Unit 1 but hvi not been incorporated into the Unit 2 design, this concern was identifud as a violation of the design control provisions of 10 CFR 50 Appendix 8 (section 7). Startup fiC d test activities were observed for the CS, RHR, D-G, recirculation pump anu integrated recirculation system flush. The testing was performed in accordance with the appropriate administrative and technical requirements (section 8). Further Bechtel SALP improvement plan actions were reviewed (section 9). The conduct of the IDCA was monitored (section 10). The installation of a feedwater sparger and CRDMs was observed (section 11). The identification of deficient conditions by PECo and Bechtel QA was reviewed (section 12).

2.0 Plant Inspection Tours (70453, 52053, 51c53, 70311, 37055, 49063)

The inspector observed in progress work activities, completed work, and plant status in several areas during inspection tours. Work was examined

, for defects and compliance with regulatory and licensee requirements.

l Particular note was taken of the presence of quality control inspectors l and quality control evidence such as inspection records, material i

identification, nonconforming material identification, housekeeping and

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equipment preservation. The inspector interviewed craf t supervision, l craft and quality control personnel in the work areas. Observations are l noted below:

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The inspector witnessed calibration checks of the load switches for the auxiliary hoist on the refueling bridge. The work was perfurmed to Startup Work Order (SWO)-281A-009, in order to resolve Test Exception (TE) 2 to Preoperational Test (POT) 2P81.1 "Feel Handling System," The TE was written when the load switch setting (400250 pounds) would not allow the 340 pound test weight to be lifted. A calibration check nowed the load switch to be tripped at a value greater than the test ,teight. The inspector independently verified the trip point calcinatio The load test was subsequently reperformed after the load suitches were reset to allow lifting the test weights. The switches were then rechecked and verified to be within the specified to' rance from the nominal set poin These mechanical switches s peared to be sensitive to the manner in which the hoist was opera.ad. "Jogging" the drive motor results in the switch mechanism changing state, which causes trips at a lighter load. The switch mechanism response does not allow reset as the

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load was not reduced 200 pounds below the trip set point. There are curreatly plans to replace the mechantcal switches with solid state electronic load switches which should result in a permanent solution to the difficulty,  ;

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The inspector observed the setting of the electrical and mechanical stops on the scoop tube positioner for the A Recirculation M-G Se The work was performed to SWO 264A-30, and used the settings obtained during the Unit 1 preoperational test. This produced settings close to those desired, in order to avoid exceeding equipment limitations during the initial pump run The inspector attended a Test Review Board (TRB) meeting to review i preoperational test procedure 2P-59.1, Revision F, "Containment Isolation and Nuclear Steam Supply Shutoff System." Licensee personnel represe.n.ed the TRP, General Electric, PECo engineering and field -

engineering. The procedure Md been previously reviewed on two occasions by the TRB. The incorporation of the previously identified changes was verified by the review pane The inspector had no concern The inspector was informed that an NRC design review had identified a potential problem with respect to the RHR pump motors. A postulated loss of off W e power would result in a reduced bus voltage which could cause an overcurrent trip of the motor circuit breaker. The inspector met with PECo electrical engineering ,

representatives and discussed Bechtel calculations 6900 E.05B and 6380 E.08. The RHR motors were procurred to be able to accelerate i to rated speed while the supplied voltage was 75% of normal. PECo determined that the minimum bus voltage during a lost of offsite power and simultaneous forced shutdown situation would be 79% of 4160 volts. The resulting voltage at the motor, inclusive of line !

losses, would be approximately 81% of the rated motor voltage (4,000 i

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volts). The existing time-current characteristic curves in the calculation bound this condition and this would not cause an overcurrent tri PECo has issued SDR 251-1 to track this issu The Unit 1 and Unit 2 inspectors reviewed the calculations and found no outstanding operability concern The inspector identified a loose bolt on the standby diesel generator A skid mounted lube oil discharge pipe stress cone fittin No laak of lube oil was found. The system engineer promptly had the bolt properly tightene The inspector observed bolt torque operations on RHR piping HBB-218-7 flange M- The hydraulic torque machine was used to perform a fourth pass torque to 750 +/- 75 ft-lb The QC inspector was intersiewed, the work package was reviewed, and calibration control of the torque machine was verifie The inspector had no further question . _ _ _ _ - _ _ _ . - _ __ . - _________- _

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3.0 Licensee Action on previously Identified items (292700, 292701, 292702} (Closed) Construction Deficiency Report (81-00-06): Limitorque motor operator defects. The inspector reviewed the following documents:

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PEco Significant Deficiency 38

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Bechtel Quality Action Request 477

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Bechtel Procedure FM-4, Limitorque Rework Program The inspector verified that all Unit 2 safety relatea valve motor operators were processed through the limitorque rework program. The rework program accomplished the following aspects: replacement of terminal blocks with direct splicing to motor leads, replacement of defective rotors, replacement of fiber shims in torque switches, replacement of damaged gaskets, removal of heaters, replacement of main gear box housing grease and installation of prepar drain plug Based upon the extensive rework program this item is closed, pen) Unresolved Item (87-02-02). Control of GE Service Advice Letters. The inspector was informed that PECo will track SALs in a similar manner to other GE issued industry notifications such as SIL The inspector requested the licensee to provide a description of the 35 SALs that were found applicaole to Unit 2 and to address the physical inspection of the HFA relays for potential mispositioned stop tab This item remains ope (0 pen) Violation (87-11-09): Undersized raceway support weld The inspector reviewed the following documents:

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PECo Finding report IN-573

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NCRs 12547, QA-L-017, QA-L-014, QA-L-026

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Apparent Discrepancy Notific' tion L-025, 0-022 The licensee re-reviewed weld inspection reports and engineering documents to identify field installation that utilized skewed fillet welds for Unit 1 support Bechtel reviewed the Unit 2 supports and found additional weldment had been specified which negated the need for the skewed fillet weld Pending review of the Bechtel calculations for the Unit 2 supports this item remains open, [ Closed) Construction Deficiency Report (88-00-09): Internal conduit seals. The inspector reviewed the folicwing documents relating to this issue:

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Evaluation of Reportability - 50R #236-2 dated August 16, 1938

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Engineering evaluation of three-hour internal conduit fire seals dated August 12, 198S

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Engineering evaluation of three-hour internal conduit fire seals dated August 22, 1988

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The qualification test data and engineering calculations demonstrate that; the as-installed seals are adequate to meet the requirements stated in the FPER. This item is close .0 Licensee Action on Bulletins and Circulars (392703}

The inspector reviewed licensee records related to the Bulletins and Circulars identified below to verify that: the Bulletin or Circular was

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received and reviewed for applicability; a written response was provided if requireo; and the corrective action taken was adequate. The following i Bulletins and Circulars were reviewed: i (Closed) Bulletin (76-04): Cracks in cold worked piping at BWR The inspector reviewed the following pertinent documentation:

i Bechtel Letter BLP-45102 dated September 14, 1988

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PEco Memorandum PMOM-2283 dated September 19, 1983 The inspector determined that the problem described in the bulletin i should not occur at Limerick 2 since the licensee confirmed that no austen1 tic stainless steel pipe or fitting located in the reactor coolant pressure boundary had been subjected to cold bendin This item is close ' (Closed) Circular (80-25): Operating problems with target-rock f safety-relief valves at BWR The inspector reviewed the following  ;

documents related to the bulletin:  !

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GP-1, Preparations for Normal Plant Startup, Rev. 4

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PECo Letter PLG-1594, dated October 27, 1986

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GE Letter PE-3492, dated December 3, 1986

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PECo Letter PLG-1601, dated December 16, 1986

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PEco Letter PLG-1606, dated February 20, 1987

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Bechtel letter BLP-39913, dated March 13, 1987

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PECo Letter PLG-1665, dated February 1,1988

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PECo M(morandum PMOM-2265, dated September 12, 1988

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ST-4-041-210-2, Main Steam Relief Valve Test The inspector determined that the main steam safety relief valves I which will be used at Limerick 2 use an actuator of an improved design which is not assembled with adhesives and can withstand pneumatic pressures higher than those which calculations show might i occur in the nitrogen system. In addition, at least one-half of the i valves are tested every 18 months and general plant procedure GP-1  !

requires a special surveillance test for any valve which failed to  !

function as designed during the reactor shutdown evolution. This l ttem is close i i (0 pen) Bulletin (8S-05}: Nonconforming material provided by Piping  !

Supplies, Inc. The inspector reviewed Bechtel memorandum FME-7854 I that described Unit 2 site investigations to dat Safety related i

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piping system records have been reviewed for evidence whether the nonconforming material described by the bulletin had been use Each stainless flange was tested with a portable alloy analyzer and the carbon steel flanges were hardness tested. A total of 312 carbon flanges and 13 stainless *langes were tested. The hardness results were converted to equivalent tensile strengt The inspector reviewed the matrix results for material heat code versus tensile strength. The site results are under Bechtel engineering review. This item remaint ope .0 Three Mile Island Action Plan Items (5254018) (0 pen) I.C.1: Short term accident procedu.'e The inspector reviewed the following:

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NUREG 0737

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FSAR section 1.13 and question 440.18

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SER section 13.5.2.3 and SSER section 13.5. Administrative procedure A-94 The NRC staff has previously reviewed the administrative guidelines for generation of E0Ps and found them acceptabl The inspector was informed that PECo engineering is currently reviewing the Unit 2 plant specific setpoint calculations to revise the TRIP procedures. This item remains open pending generation of the revised TRIP procedures which will conform with revision 3 of the Boiling Water Reactor Owners Group (BWROG) guidelines.

i (0 pen) I.C.5: Feedback of operating plant experienc The i inspector reviewed the following:

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FSAR sections 1.13 and question 630.32

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SER section 1 SSER 1 section 13

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PECo Interim Nuclear Group Administrative Procedure for Operating Experience Assessment Program (OEAP)

The corporate and site program and organization responsibilities for review and dissemination of operating experience information had been previously reviewed and accepted by the NRC staff. The new OEAP has superseded elements of the previously described program, This item remains open pending revision of the FSAR to reflect the OEAP and development of implementing procedures for corporate and site organizations, (0 pen) 11.0.3: Safety relief valve position indicatio The inspector reviewed:

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Limerick FSAR sections 1.13, 7.5.1.4.2.2.1, 7.6.1.5 and 7.6 _ _ _ _ __ ._ . _ _ _ _ _ - _ - _ _ _ - _ _ _ _ _ _ _ _ _

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Limerick SER 7.5. The inspector examined the installed valve position. indication devices in the control room and confirmed that indications are provided for valve open, closed and valve was open position The FSAR indicated the acoustic monitoring system was installed in accordance with the QA progra The inspector was informed that the Unit 2 acoustic monitors are located in the warehous A design change will be issued to clarify the ambiguous Quality Assurance 01agram (QAD) description of the quality program coverage for the sensors. The work packages and quality reports had not yet been generated for the sensors. The inspector was informed that an Apparent Olscrepancy Notification (ADN) has been issued to alert the Unit 1 staff of the potential lack of quality overview for the Unit 1 sensors. The inspector noted that while the FSAR stated that all system components except the power supply are seismically qualified, the SER erroneously states that the power supply is seismically qualified. This item remains ope d. (Open) II.E.4.2

Containment isolation dependability. The inspector reviewed the following pertinent documentation:

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NUREG 0737, Clarification of THI Action Plan Requirements, enclosure 3, section II.E. FSAR section 1.13

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Limerick SER section 6.2.4.3 l

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Supplement 6 to the timerick SED, section 6.2.4 l

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NRC letter, Butler to Bauer,. dated May 20, 1986 l

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PECo letter, Kemper to Butler, dated June 20, 1986

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NRC letter, Butler to Bauer, dated August 22, 1986

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PECo SDR #385. dated January 3, 1984 l

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PECo letter PLB-21894, dited May 5, 1988

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Bechtel letter BLP-44006, dated June 13, 1988 l

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PECo letter PLB-22913, dated September 9, 1988 The NUREG 0737 clarification states that the isolation function

! must be performed automatically with no credit for operator l action. Containment isolation valves at Limerick have been l identified as being susceptible to the MCC circuit breakers I tripping when the valve motor receives a closure signal while l

running in the open directio This situation will require i operator action to reset the circuit breaker. This item remains open pending resolution of the issues surrounding the circuit breaker trip on motor reversal phenomeno Construction Deficiency Report 83-00-06 documents the licensee identified problem with the circuit breaker trip phenomen e. (Closed) II.K.1.5: Assurance of proper engineered safety features functioning. The inspector reviewed the following pertinent documents:

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FSAR section 1.13

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Limerick SER section 15. Supplement 3 to Limerick SER, Section 15. A-8, Procedure for Control of Locked Valves and Device Revision 4

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A-26, Procedure for corrective maintenance, Rev.13

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A-41, Procedure for control of plant equipment, Rev. 6

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PEco Letter, Bradley to Schwencer, dated May 11, 1983 The inspector determined that the staf f approved the methodology of including controls on equipment in administrative procedures in the SER. A confirmatory item was noted to verify that the contents of the procedures covered the issues. This confirma-tory issue was closed in SER Supplement 3. The inspector verified that the procedural controls have been maintained in the current revisions. This item is closed.

' (Closed) II.K.1.10: Operability status of safety related systems. The inspector reviewed the following pertinent documents:

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FSAR section 1.13

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Limerick SER, section 15. Supplement 2 to Limerick SER, section 15. PECo Letter, Bradley to Schwencer, dated May 11, 1983

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A-41, Procedure for Control of Plant Equipment, Rev. 6 In the SER, the staff accepted the methodology of including controls on safety-related equipment in an administrative procedure. A confirmatory item was noted requiring verification that the procedure addressed the issues surrounding knowledge of status of safety-related systems. In supplement 2 to the SER, the staff approved the procedural elements of A-41. The inspector verified that these controls and independent veri'ication requirements have been maintained in the current revision of A-41.

" (Closed) II.K.1.22: Auxiliary heat removal syste This item relates to the ability to cool the reactor on a loss of feedwater transient. The inspector reviewed the following documents applicable to this issue:

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FSAR section 5. FSAR section 5. FSAR section 6.3. FSAR 1.13

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Limerick SER section 15. Supplement 3 to Limerick SER section 15.9.3

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This issue was accepted as satisfactorily resolved in the initial SER and Supplement 3. Since that time, PECo has opted to disable the steam condensing mode of the RHR system in ,

response to staff concerns regarding water hammer potentia ,

As a result, Limerick has three separate and redundant means of '

cooling the fuel on a loss of feedwater: RCIC system operation (automatic or manual), HPCI system operation (automatic or manual) and a combination of automatic depressurization system and either core spray or LPCI operation. If the reactor is isolated in addition to having a loss of feedwater flow, safety-relief valves are available to control reactor coolant system pressure via automatic or remote manual operation. This item is close (Closed) II.K.1.23: Reactor vessel level. This item was related to instrumentation avetlable for indication of reactor vessel water inventory, allowing operators to recognize and assess feedwater transients and small break loss-of-coolant accidents. The details of the staff's evaluation are contained in NUREG 0626. The design was accepted for all BWRs and is documented in Section 15 of the Limerick Safety Evaluation Report (SER). This item is close . (Closed) II.K.3.13: Separation of high pressure coolant injection and reactor core isolation cooling system initiation levels. The inspector reviewed the following documents:

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NUREG 0737

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Limerick FSAR sections 7.4.1.1.3.2 and 1.13

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Limerick SER and SSER 2 section 15

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Letter from John Kemper to A. Schwencer dated 5/22/84

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RCIC elementary diagram 791E421TR

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RCIC preoperational test procedure 2P-5 The inspector confirmed that the RCIC system is initiated automatically upon receipt of a low Reactor Pressure Vessel (RPV) water level (level 2). When the RpV level reaches level 8, the steam supply valve for the RCIC turbine is close The system will automatically restart upon receipt of a second low RPV water level signal. Section 6.4.1.16.4 and 6.4.5.2 of preoperational test 2P-50.1 will verify proper operation of the RCIC system components. This item is close J. (Closed) II.K.3.18: Modification of Automatic Depressurization System (ADS) logic for increased diversity. The inspector reviewed the following documents:

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NUREG 0737

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Limerick FSAR section 1.13

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Limerick SER section 15

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General Electric FDDR HH2-3739

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General Electric design specification 22A2919AD

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Elementary diagram 791E403TR, Auto depressurization system

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The inspector confirmed that a manual inhibit switch has been designed for each ADS division. The inhibit switch actuation prohibits the ADS two minute timer from advancing or resettin A status light and alarm are also provided for the switch inhibit positio The ADS design was also changed to provide a seven plus or minus 1/2 minute timer for a bypass of the high drywell pressure contacts. This ensures that a break that does not produce a high drywell pressure will initiate the ADS actuation sequenc This item is closed, (Closed) II.K.3.24: Confirm adequacy of space cooling for high pressure coolant injection and reactor core isolation cooling system The inspector reviewed:

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NUREG 0737

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FSAR sections 1.13 and 9.4. SER section 9.4.2 l

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Bechtel drawings E-16. E-24 and E-67 The inspector confirmed, through review of the AC electrical distribution system drawings, that the associated unit coolers and associated cooling water system components are powered from l onsite emergency power sources. The space cooling system will l perform its design function after a complete loss of offsite AC power. This item is close .0 Spent Fuel pool Racks (250095]

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Specification M-115 (PEco) 2-1

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Quality Control Inspection Report (QCIR) 20-5276-45-1 l

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Drawings C-778, M115 (PECo)-28 and M115 (PEco)-29 l

I The spent fuci racks are free standing assemblies. The inspector l

examined the installed racks for the following attributes:

location, spatial separation, cleanliness, bottom clearance from the l fuel pool liner, bearing plate dimensions and welding, rack serial l nu'nber, and corner angle clip bolting and rivet The Bechtel work package governing the rack installation was found l to include the appropriate vendor instructions for the rack l installation. The QCIR was found to contain appropriate inspection attributes for the racks.

Both the Bechtel construction engineer and quality control inspector were interviewe The Bechtel personnel were knowledgeable of the

, installation requirements and the current installation status of the i rack assemblies.

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The inspector reviewed civil calculation 22.78-3, "Bearing Plate for !

Spent Fuel Pool Liner Plate." The maximum rack bearing load was provided by the vendor (par) which included dead weight of the rack and fuel, hydrodynamic mass, impact and seismic loads. One inch ,

thick bearing plates were provided at several locations since the legs were directly over a section of the liner plate where a leak chase channel existe The bearing stresses were checked for locations without a bearing plate and were found satisfactory for the concrete foundatio t Based upon examination of the installed racks and the review of ,

associated quality engineering and construction documentation and !

the interviews with cognizant personnel, the inspector observed no violations and found this activity well controlle .0 Preoperational Test Procedure Review (370311) j The inspector reviewed preoperational test procedure 2P 58.2, "Redundant Reactivity Control System (RRCS)." Additional documents reviewed included:

FSAR section 7.6.1.8, GE preoperational test program data sheet (22A2271AY i Rev. 3), and GE drawings M-1-C22-1050-E-143.3 through 185.2, M-1-C32-1020- '

E-006-(5) 3, M-1-C22-4010-H-001.9. Several deficiencies were noted. The !

deficiencies and actions taken to resolve them were: 1) The GE preoperational [

test specification required verifying that rod position indication was [

available for one hour after a loss of power. A field deviation disposition request (F00R) is being initiated to delete this requirement since the i power supply at Limerick is a battery bus, via an inverter. 2) FSAR diagram !

7.6.10 showed the APRM not downstele trip as a part of the input for RRCS f ready for reset. A licensing document change notice (LOCN) is being [

initiated to correct the diagram. 3) GE Elementary Drawing M-1-C32-1020- i E-006.3 shows the division 1 FV runback circuit initiating a runback of j the A and 8 feedwater pumps, while the division 2 circuit initiates a (

runback of the C feedwater pump. This is not consistent with FSAR section ;

7.6.1.8.3.3 and GE specification 22A7477 that state that feedwater flow i will be reduced to 0 percent within 15 seconds by either logic divisio j This constitutes a violation of 10 CFR 50, Appendix B, Criterion III which !

rettuires measures to be implemented to ensure that the design basis !

documented in the license application is correctly translated into the design drawings. (88-25-01)

In response to this discrepancy, the connection drawing and field installation were checked, and found to conform with the erroneous elementary drawing. The POT was checked to determine if it would identify this deficiency, and was confirmed to do 5 Unit 1 FDDRs for the redundant reactivity control system (RRCS) were reviewed, and it was determined that this deficiency was identified, corrected on Unit I and designated as applicable to Unit 2. Further review of Unit 1 FDDRs identified as being appitcable to Unit 2 nas been initiated to ensure that appropriate Unit 2 FDDRs were generated and incorporated into the Unit 2 design drawing _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - -

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8.0 Startup Testing Activities _._(70315, 70441, 70459, 70436, 70302, 71302) '

a The inspector witnessed portions of the core spray system logic testing. The inspector noted that portions of the testing were being performed out-of-sequence and that this was documented by test change notice (TCN) as required in AD-8.3P, "Preoperational Test Implementation." A problem was noted in the arca of control of  ;

modifications when the out of sequence testing was done. A modifi- l cation installed in step 6.4.2.1(22) which would normally remain in f place for the duration of that portion of the logic test prevented the performance of the minimum flow valve logic testing, step l

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6.4.2.1(3), which was performed out of sequence after step 6.4.2.2(62).  ;

The test engineer readily determined and corrected the cause of the  !

difficulty in this instance, and no testing was invalidated since the  !

first procedural step in the out of sequence step performed did not i i work as anticipated. During this sequence, a logic timing relay was .

1 determined to be outside its specified range. This was documented ,

on a TE #4, and testing continued. All other steps in this group  ;

i were carried out satisfactoril The inspector noted that an extra  !

1 precaution of a generic nature not listed in the procedure was being  !

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followed. Some Limitorque motor operators were supplied with limited l duty-cycle motors. In order to avoid damaging these motors, all l Limitorque MOVs were being allowed to cool for one half hour af ter j two cycles of operation (full closed to full open and return) in a short time perio No other problems were note !

b The inspector observed portions of the preparations for, and conduct of, the initial run of the A recirculation pump conducted as part of  ;

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the reactor recirculation system POT. It was noted that the test  !

approach was careful and conservative, with a hold put on the test l

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on several occasions while determining that occurrences in the plant  !

were not related to this test. No significant problems were l identified, t i

F c The inspector monitored preparations for the integrated flush t including valve line-ups, blocking open the MSIVs and vessel fil l One minor diffic'alty was noted when a boundary valve leaked by and  :

. resulted in wetting the drywell floor. It appears as though the  !

valve did not stroke fully closed when operated using the moto l This valve was subsequently closed and a tight shutoff obtained. A {

SWO has been generated to check the setting of the torque and limit *

i switches using MOVATS.

Conduct of the integrated flush was well-controlle It was necessary to si*ghtly modify several flow paths to get adequate '

cleaning, n'ost notably on the main steam lines. Appropriate TCNs were generated to document these changes. Flush path samples for sevtral flew paths were witnessed by a regional specialist inspector ll and will be documented in IR 50-353/8S-2 li

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i d The inspector observed portions of the bearing run-in and vibration reduction work on the 0 0-G. It was initially thought that the high

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vibration on the engine was due to excessive backlash in the gears on the vertical drive. This backlash was checked with satisfactory results. Attempts were then made to rebalance the generator, which i resulted in a reduction of vibration. The bearing run-in was

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continued, and a further vibration reduction resulted when the generator was loaded. During the periodic inspections, the #10 lower bearing was determined to have failed. See IR 50-353/88-22 for details. It was replaced, and further runs were completed without difficulty, e The inspector witnessed portions of the RHR preoperational system testing (2P-49.1). The completion of the test prerequisites was verified through review of the test results package. The inspector attended the briefing for the shift startup engineer and operations personnel. The inspector witnessed logic testing and operation for

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the following valves:

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Valve --Description HV-51Tff5A Loop A and C f'ull flow test line i

HV-C-51-203B 2B RHR heat exchanger outlet bypass

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HV-C-51-203A 2A RHR heat exchanger outlet bypass HV-51-2F021 2B RHR containment spray inboard MOV The following aspects were confirmed during the test: valve stroke 4 times, valve operation from the control room hand switch, simulated t

system response to accident conditions and verification of valve a position control room indication. The test engineer performed the testing in accordance with the test instructions. The test engineer

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was thoroughly knowledgeable of the system characteristics and properly utilized the test change and exceptions during the course

, of the testing.

$ f The inspector observed portions of the standby diesel generator 023

preoperational testing (2p-24.1). Personnel were present during the test from PECo field engineering, PEco instrumentation, operations, 1 Plymouth Labs, PECO QA and QC, The inspector accompanied test personnel during the switch position verification prior to running the test. The inspector reviewed two safety evaluations regarding isolation tag removal to support the desired testing. The inspector observed initiation of the diesel p.'elube pump cycle and simulation of a LOCA start signal and energization of engine start relay ESS i The engine response parameters including: rpm, generator voltag l ready to load relay energized, watts, vars, air start solenoid energized, engine overspeed and low speed relays energized were

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recorded on a strip chart recorde The engine reached rated speed and voltage in 8.7 seconds, i

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--- ,.-..,-n, ,-- - - - - ---,e-.,,-.- ~,.-,..,-wn,,-wn--.-,-------m-

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The test engineer performed some logic testing followed by a one hour engine run at 50*4 power. The testing was repeated utilizing relay ESSB to provide the engine start signal. The engine start was verified for a loss of offsite power to the bu The inspector reviewed strip chart recordings that indicate the engine reached 900 RPM in 7.2 second The engine was loaded to 100*4 for one hour then a load reject test was performed. The inspector verified the engine governor maintained generator voltage below 4784 volts. The inspector observed PECo quality control performing the requisite inspections of system restoration The observed test activities were performed in a controlled manner with requisite quality oversight coverage. No unacceptable conditions were identifie .0 Engineering (37055, 52051, 52053, 52055)

a The inspector reviewed Bechtel engineerir.g actions resulting from the SALP improvement program. Bechtel performed self-evaluations with the Intent to enhance the ability of engineering to detect gnd correct problem areas within the design proces The first summary report (Bechtel letter BLP-45025) regarding the areas investigated by Bechtel was reviewed by the inspector. Three key areas of FSAR accuracy, design interfaces and quality assurance inputs were discussed. Engiraering procedures have been revised to provide more effective control ovtr LOCNs that are used to revise the FSAR, licensing coordinators were assigned to thoroughly review design changes for FSAR impact, .ind FSAR code commitments were rereviewed to ensure accuracy with the as-built plan In the area of design interfaces, Bechtel evaluated seven multidiscipline design changes, 10 construction interface areas and a review of plant mirror slide along layout. The review process for Project Change Notice was expanded to include all engineering groups to prevent incomplete inter-disciplinary review Piping calculations for common syste'ns were re-reviewed to ensure that the Unit 2 configuration was properly depicted. A design interface agreement was developed between Bechtel and GE. Also as a result of quality assurance problems identified a common concern with lack of procedural adherence. Bechtel has developed upgraded training to assure employee understanding of the governing engineering procedure The inspector attended a meeting for the Design Process Improvement Program. Recent engineering issues were discuss (d and the associated investigations or corrective actions were presente The meeting appears to provide a unique forum for engineering nanagers to discuss the results of introspective reviews of the engineering effort _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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The engineering initiatives appear to be responsive to the problem l areas identified through ooth NRC and licensee channels. No violations were identifie i b The inspector accompanied personnel from Bechtel engineering during [

a walkdown of installed components outside containment. The )

walkdown was performed to gather data to assure the environmental l qualification requirements were satisfied by the field t configuration. The following components were examined: (

i Location Item l panel 2R 208 Agastat relay KMF2078  !

panel 2AC208 Agastat relay KS77-207C, wire fiberglass !

sheathing and AMP terminal board  !

panel 20C207 Agastat relay KS76-294A panel 20C901 Vulkene SIS wire panel 2BC224 Buchanan terminal blocks The inspector reviewed specification G-47 and the checklists that were generated for the above items. The licensee identified some conduits lacking an internal :eal at the junction with the enclosures. The inspector was informed that the field would install the seals. The examination was performed in a detailed mannor and the checklists were supplemented by photographs to depict the field configurations. No violations were identifie .0 Independent Design and Construction Assessment (251053, 235060. 49063

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T90W~ DMO. $00T375M3)

The inspector continued to monitor the conduct of the Stone and Vebster Engineering Corporation (SWEC) Independent Design and Construction Assessment (IDCA) activities. The last week of the SWEC onsite construction assesseent effort was observe The SWEC inspection of instruments and instrument tubing in accordance with review plan LK-C-1908 was observed.

I The inspector additionally reviewed the radiographic film that had been identified in SWEC observation report COR-001 and action items CAI 005, 022, 023, 024, 025 and 026. The inspector found that only the radiographic film associated with field weld 6 of piping isometric OLA-212-2 contained an indication representative of a condition that is unacceptable to the criteria of ASVE Section !!!.

The SWEC inspection of metiianical components in the spray pond pump house was monitored by the inspector. The inspector noted a thick grease like substance drioping out of electrical conduit OBp543. When questioned by the inspector, PECo initiated QA finding 2N-626 and determined through chemical analysis, that the substance was flax soap which was used as a cable pull lubricant. pECo additionally issued finding 2G-765 since the

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material was not on the site hazardous / controlled material list. The material was subsequently approved for use with certain discharge and personnel protection restriction The inspector continued to overview the SWEC action items, observation reports and the Bechtel responses to the SWEC concern .0 Reactor Vessel Internals (50051, 50053, 50055)

The inspector reviewed the following documents related to the installation of the reactor pressure vessel (RPV) internals:

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GE Specification 22A4111

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GE travelers 2-280T, "Feedwater Sparger Installation" 2-206T "Control Rod Drives"

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GE drawing 197R626 The installation of the 150 degree feedwater sparger was observed by the inspector. Representatives from GE project engineering and quality control were present. The sparger was soaked for an appropriate length of time in the nitrogen bath. The sparger was inserted into the proper nozzle and thermal expansion creates an interference fit. The thermal

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I sleeve and piston rings were dunked into the nittogen bath. The temporary compressive rings were removed and tna sparger end was soaked in the nitrogen bat The sparger was inserted into the nozzle without having to utilize the available hydraulic ra The inspector additionally observed preparatory crew trainin The installation of selected CR0s was observed by the inspector. In particular CRDs 22-43, 26-43, 42-19 and 46-19 were monitored. GE quality control personnel were present and performed the requisite inspection The t-aveler and special process control shuts were properly recorde The CR0s were carefully handled, cleaned and inserted into the appropriate locations with the necessary gasket material. The CR9s were temporarily bolted in plac QC performed thorough examinations in particular to ensure the CRD flange surface was flush prior to bolt up. Both work operations wer7 properly controlled by GE and no violations were observe .0 Deficiency Reports (35060)

The inspector reviewed selected deficiency reports identified within the Bechtel and PEco quality assurance program. Bechtel generates MCARs for adverse conditions that may be reportable to the NRC. The inspector reviewed MCAR 1-42 regarding 16 flow sensors that were not sealed in accordance with the associated qualification configuration. Water entry into the flow sensor could cause a failure that would disable the drywell unit coolers. New gasketed flow sensors have been procurred for Unit 2 to eliminate the problem. Additional examinations will be performed to ensure tnat devices are installed in the qualified stat _ . _ t

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PECo SDR 244-2 was reviewed with regard to the flow sensor problem. PECo t

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determined the deficiency was not reportable based upon an analysis that i I showeo sufficient drywell mixing would occur following a LOCA to prevent !

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hydrogen and oxygen stratification without drywell cooler fan operatio !

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I, The flow sensor problem was determined to potentis11y erist on Unit 1.

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The licensee has taken compensatory measures to bypass the flow sensors ;

, so the drywell fans are enanually controlled after the concern was  ;

transmitted to the plant staff on September 24, 1988. This issue was i

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determined to potentially apply to Unit 1 on August 10, 1938 and a JC0 ,

a was transmitted to PEco engineering on August 22, 193 I l

The inspector aJditionally reviewed MCAR 1-43 regarding conductive  !

, Westinghouse motor starter insulation that caused a short circui Four i j wiring compartments were found on Unit 2 with the defective wiring which [

l was subsequently replaced. No di?crepancies were found on Unit I wirin l

! The inspector was informed PECo has issued SDR 250-2, and this item has -

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been reported to the NRC.

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Numerous PFCo SDRs were additionally reviewed as follows:

' SDR Description i

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2W2 Hot air bath calibration method led to incorrect calibration of f bulb and capillary type instruments. The affected instruments j were reviewed by the licensee for operability concerns and non

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were identified,

242-2 Radiographic film for RHR pipe weld OLA 212-2 FW-6 indicates I

an unacceptable indication. Th;s is still under revie l

{ 245-2 Damaged terminal blocks were found within level switches. This a is still under review.

, 247-2 Eight mounting bolts or welds were missing on a 4S0 V loaa

cente The as-built condition war, analyzed by engineering and

! found acceptabl !

! 248-2 Some meter relay panels were incorrectly classified by GE as i j non-!E for the standby liquid control system. This is still l

under review.

l 249-2 *, a f t, shutdown instrumentation can be lost due to potential ;

i fires affecting tne operation of ESW valves. This item has i a been reported for both Unit I and This issue was documented t i on September 8, 19BB.

l The inspector concluded ths; adequate programs exist to ensure j significant deficiencies are identified and reviewed for potential

) reportability and ultimate correctio The issues did rot appear to be l ccmunicated in a timely m to Unit 1 operations staff in the cases j of SOR 244-2 and 249- Th a "ern is being reviewed by the Unit 1 NRC s resident inspectors..

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13.0 Assurance of Quality (40301)

During the conduct of diesel generater tetting ceteribed in soction 8 of this report, the inspector noted the PECo Senior Vice President-Nuclear per#orming a piant tour. TL_ presence of senior licensee management in the field is indicative of the level of attention and oversight provided to work activitie The failure to transfer system design change information into the Unit 2 design was reviewed in >ection 7.0. Full assurance should be maintained that design changes made during the Unit 2 su ension of construction activities have been properly incorporated into the desig Seci* ion o 0 outlines startup testing that has been performed in strict compiiance with the appropriate procedural instructions, Section 9.0 describes further Bechtel engineering initiative to perform introspective self-assessments to identify weaknesses in the engineering are The lack of timely transmittal of potentially adverse information to the operating staff was discussed in section 1 The NRB met at the Limerick site on October 6, 1988, to review safety and operations issues for both Limerick and Peach Bottom. The resident inspector attended portions of the discussion of Unit 1 Operations which might affect Unit 2, and the discussion of the Startup Program. The NRB was presented with a briefing on recently TRB and QA approved preoperational test results package.s. The NRB also requested an update on the status of work related to NUREG 1275, vol. 2 on Air System Problems. The response was that a loss of air procedure had been prepared and that training on the procedure was in progress. The NRB was also presented information on the testing scheoule and status. The members expressed concern that all the drawings associah j with the various systems be complete and up-to-date at the time o' system turnover to the plant staff for operatio The members also requested information on the Unit 2 test schedule and potential impacts on, or conflicts with the Unit 1 outage schedul The Unit 2 startup manager explained the plans for ccordination with the Unit 1 outage activitie .0 Meetings with Licensee (230703B,71301)

The NRC resident inspector discussed the issues and findings in this report with members of the licensee's staff on a weekly basis, and at an exit meeting held on October 17, 1988. Based on discussions held with licensee representatives on October 17, 1988, it was determined that this report does not contain information subject to 10 CFR 2.790 restriction ~

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The inspector attended a meeting on September 30, ISOS between PECo Fire Protection personnel and the Unit 1 NRC resident inspectors. Topics of discussion included failure of the motor driven fire pump to meet the discharge head specified in the ST, failure te deliver flow at pressure as specified in FPER and FSAR, water curtain flow per unit area, and the capabilities and equipment qualification status of the ' backup' fire pump available. A PECo licensing representative indicated that revised system operability requirements were in the process of being generated based on detailed computer analysis of the installed system. It was also stated that appropriate documentation was being drawn up to eliminate the TS requirements on fire protection system and equipmen The inspector participated in a conference call on October 6,1988 with pECo engineering personnel and Unit 1 NRC resident inspectors regarding equipment located in the battery rooms. The discussion topics included incorrect information in the FPER, ambiguous statements in the FSAR, -

incorrect information in the SER, applicability of IEEE standards, capabilities of installed ventilation and alarm systems, qualification of installed ventilation systems and potential for hydrogen pocket formation.

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, APPENDIX 1 Acronyms and Abbreviati6ns AC Alternating Current ADN Apparent Discrepancy Notification ADS Automatic Depressurization System Ap Appendix APRM Average Power Range Monitor BWR Boiling Water Reactor BWROG Boiling Water Reactor Owners Group CS Cote Spray CRD Control Rod Drive CRDM Control Rod Drive Mechanism DAI Design Action Item 0-G Diesel Generator E0P Emergency Operating Procedure ESF Engineered Safety Feature ESW Emergency Service Water FDDR Field Deviation Disposition Request FPER Fire Protection Evaluation Report FSAR Final Safety Analysis Report FW Feedwat e'-

GE General Electric HPCI High Pressure Coolant Injectiu IDCA Independent Design and Construct on Assessment IEEE Institute of Electrical and Electronics Engineers IR Inspection Report JC0 Justification for Continued Operation LDCN L. censing Document Change Notice LGS Limerick Generating Station LPCI Low Pressure Coolant Injection MCAR Management's Corrective Action Requests MCC Motor Control Center M-G Mntor Generator MOV Motor Operated Valve M0 VATS Motor Operated Valve Analysis and Test System MSIV Main Steam Isolation Valve NCR Nonconformance Reports NQA Nuclear Quality Assurance NRB Nuclear Review Board NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation PCN Project Change Notice PCR Project Engineering Change Request PECo Philadelphia Electric Conpany POT Preoperational Test QA Quality Assurance QAD Quality Assurance Diagram QC Quality Control

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QCIR Quality Control Inspection Report RCIC Reactor Core Isolation Cooling RPV Reactor Pressure Vessel RHR Residual Heat Removal RRCS Redundant Reactivity Control System SAL Service Advice Letter SALP Systematic Assessment of Licensee Performance SOR Significant Deficiency Report SER Sr.foty Evaluation Report SIL Service Information Letter SSER Supplemented Safety Evaluation Report ST Surveillance Test SWEC Stone and Webster Engineering Corporation SWO Startup Work Order TCN Test Change Notice TE Test exception TRB Test Review Board TRIP Transient Response Implementation Plan TS Technical Specifications