IR 05000353/1988015

Insp Rept 50-353/88-15 on 880606-10.No Violations Noted. Major Areas Inspected:Installation of Instrumentation, Instructions,Procedures & Related Records to Verify If They Reflect Work Accomplishment Consistent with Requirements

ML20207D413
Person / Time
Site:	Limerick
Issue date:	08/05/1988
From:	Anderson C, Thomas Koshy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207D407	List: IR 05000353/1988015 ML20207D405
References
50-353-88-15, NUDOCS 8808150346
Download: ML20207D413 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /88-15 Occket N ,

License No- CPPR-107- 3

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Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Facility Name: Limerick Generating Station, Unit 2 Inspection At: _ Limerick, PA Inspection Conducted: . June 6-1.0, 1988 r Inspectors: b T 4.3fy ~

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Thomas Koshy, Senior Reactor Engineer date Approved by: C)

C. f. Anderson, Chief, Plant Systems Section F!5~ 6-

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date Inspection Summary: This inspection was to review the installation of-

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instrumentation, instructions, procedures and the related records to verify if they reflect work accomplishment consistent with NRC requirement Results: The inspection concluded that the licensee's instrumentation installation was in compliance with the instructions and procedures established l by the' licensee and was in agreement with the Safety Analysis Report. One ite".

remained unnsolved that dealt with the processing of wiring deficiencies and

! t e review of reportable items. This is discussed in detail in Section 5 of-l tnis report.

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8808150346 880805 PDR ADOCK 05000353

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i DETAILS l'.0 . Persons Contacted 1.1 Philadelphia Electric Company (PEC01

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D.~D. Basile, lead Startup Engineer, QC

• J. M. Corcoran, Manager, Quality Assurance D. Cook, Construction Engineer

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D. A. DiPaolo, Superintendent, Quality Assurance, Unit 2

• R. George, I&C Engineer J. Hummer, Construction Engineer W. D. Lamsen, Quality Assurance Engineer R. Levesque, I&C Technician G. McDermit, I&C Technician J. Michael, I&C Technician J. J. Milito, Superintendent, Startup Unit 2-R. H. Slaughter, Project Quality Engineer

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B. F. Spedden, Construction Engineer

• R. D. Weingard, Lead Enginaer, I&C Unit 2 1.2 Be:htel

• B. T. Footte, Lead Construction Engineer

• L. Hale, I&C Field Engineer W. R. Halton III, Quality Engineer R. Holt', Assistant Lead Instrumentation Engineer K. J. Humme, Lead Instrumentation Engineer G. C. Kelly, Lead Site Quality Assurance Engineer

• W. W. Kircher, Lead Quality Control Engineer Piping and Instrumentation W. L. McCullough, Project Startup Engineer T. Molinaw, Project Superintendent L. J. Pons, Resident Project Engineer K. Stout, Quality Control Engineer 1.3 General Electric Company (GE)

R. D. Ballou, Group Leader, GE startup U.S. Nuclear Regulatory Commission (NRC)

R. A. Gramm, Senior Resident Inspector

• Not present at the exit meetin '

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2.0 Purpose The purpose of th;; inspection was to review the instructions and

. procedures for installing safety related instrumentation and to examine the related records to ascertain whether there records reflect work accomplishment' consistent with NRC requirements and licensee commitment .0 Facility Tour'

The inspector observed work activities in progress, completed work and plant status in several areas during a general inspection of the sit The inspector examined work items for obvious defects or noncompliance with NRC requirements or licensee commitments. Particular note was taken regarding the presence of quality control inspectors and indications of quality control activities through visual evidence such as inspection records, material identifications, nonconformance and acceptance tag In addition, the inspector interviewed craft and supervisory personnel encountered in the work are No discrepancies were-observe .0 Review of Instrumentation and Tubing Installation (Module 52051)

The inspector reviewed the Quality Centrol (QC) log for completed installation and randomly selected the following six inspection records for a detailed review. The respective work instruction packages were also collected in order to review the adequacy of technical instructions, specifications, QC inspection attributes and the documentation generate Work Package No: JTR-42-07-34Q-B Rev 0. Install tubing and supports from process taps to Panel 20-C026 for A1, A2, A4 ar.d AS. QC inspection record J-0012 Work Package No: JTL-50-04-27Q- Install Tubing and Support for LSH-50-210. QC Inspection Record No. J0005 Work Package JML-20-29-11Q- Install Pressure Switches PS-20-2260-1, 0-2 and the required tubing and supports. Inspection Record J0024 Work Package JME-20-29-02A-A Install LSHL-20-221A and LSHL-20-223 Inspection Record J00293.

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Work Package JME-20-29-14Q-A Install SHL-20-2210 and LSHL-20-222D.

l Inspection Record J00277.

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Work Package JTL-20-29-11Q- Install tubing from the starting air compressor to PS-20-226-B-1, B-2 Inspection Record J0024 . - . . - , . . - . . - . _ . - . - , - _ - . _ . -

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'i The inspector verified thst these work packages conform to the guidelines in drawing M-830-G000. The QC inspection attributes'were adequately inspected and documented. The inspector observed that the installation requirement to clean the sensing lines by blowing dry air before

. connections are made, was not documented and the work instructions did not require ~ documenting this activity. The QC inspectors were not required to witness this activit In order to, preclude the concern on the lack of sensing line clean up, the Startup Technical. Program TT1.8 Revision 0, has a procedure to perform instrument line routing verification and flushin The inspector selected the following 3 work packages from the above group to verify the as built configuration through field walkdow * JTL-50-04-27Q-A. Level Switch LSH-50-210 connected to the drain port in the Reactor Core Isolation Cooling syste * JML-20-29-11QA Pressure Switches for Emergency Diesel Generator Starting Air Compresso ,

• JTR-42-07-34Q Tubing for Reactor level instrument CT-42-2N0810 at General Electric rack H22-P02 The inspector verified the following attribute * Unsupported length of the tubing does not exceed 60 inche * High and low connection to the instrument are done correctly

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and are in accordance with the drawin <

• Recommended minimum slope of 1/4 inch per foo * The direction of slope is in accordance with the process requirement * Bends are uniform and the ovality is within toleranc * Final installation conforms to drawing * The prescribed fittings are utilized and that the fittings are avoided at the bends as specifie The inspector noticed that the tubing for Reactor level instrumentation Al and A2 at instrument rack 20C026 (H22-P026) was touching each othe This was due to a temporary power cable pulled above this tubing which resulted in a loose Bulkhead fitting. The licensee promptly generated Nonconformance Report 13502 and dispositioned it before the end of the inspectio The discrepancy was an isolated case and the subject installation was not completely turned over to startup.

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PECo agreed to provide special attention in the routine training to exercise the necessary precautions to prevent damage to the installed equipment. The licensee has a program to walkdown the system tubing to look for such discrepancies and correct them before the system is turned over to startu No other discrepancies were observe .0 Record Verification (Module 52055)

The inspector revieweri the licensee files on the processing of design changes, non-conformances and deviations. The inspector selected the two following documents for further revie *

Startup Field Report 251A-002, Core Spray System wiring change to disable the operator control on an injection throttling valve during initial actuatio * Startup Field Report 251A-001 Wiring change in the annunciator circuit of the Core Spray Syste PECo has 3 procedures to perform design change . AD Startup and Field Report Procedure (SFR),

Revision 3 LGS-QC1-010 Preparation of Noncon 4 rmance Reports (SNCR)

Reports (SNCR), Revision 5 AD 6.13 Sturtup Change Requests, Revision The licensee processed the above document using Startup Field Report (SFR) Procedure A06.3 Revision 4. The SFR procedure requires that field changes on safety related equipment be processed as SNCRs. The inspector observed that the procedure was not completely followed in that the field installation was modified without the Startup Nonconformance Repor However, this document was reviewed for reportability and was subjected to a quality assurance and quality control review. The three procedures mentioned above are very similar procedure The inspector observed an apparent confusion in the application of the above procedures in that the interviewed personnel were not clear on the use of SNC The licensee currently plans to revise these procedures for streamlining the above reference procedures for better understanding and complianc The licensee procedure "LGS-2-QAI-15-4, Startup QC Determination of Further Review for Reportability of Startup and Field Engineering Documents" was used to review SFR 51A-00 The procedure contained the guidelines to evaluate documents for reportability. The NRC inspector

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> s did not find sufficient basis for concluding that the design defect in SFR 51A-002 is not reportable in that the information available did not establish that the defect was not significant. However,' discussion with the cognizant engineer revealed that the reviewer had additional ~informa-tion to conclude this design defect was not significant and hence, not reportabie. The licensee agreed to sensitize the SFR authors and the reviewers.to document the basis for determining reportability to the NR The licensee corrective action on the core spray system logic addressed in SFR 51A-002 and performed through General Electric Field Deviation Disposition Request HH2-4403 was first identified at Limerick Station The discrepancy was that the panel wiring was different than the schematic (Elementary) drawing in that during the actuation phase of the Cere Spray Systems the functions would be disabled if the operator happened to operate the control switch. The specific problem addressed in this document was corrected. However, this schematic is typical for several throttling type ECCS valves. The same wiring discrepancy can exist at other throttling valves in the ECCS system. The licensee does not have a documented program to review other potential areas for this concer The above three items will remain unresolved pending the streamlining of procedures, sensitizing the reportability reviewers to document the bases '

and a licensee program to review other potential areas of concern during the processing of a safety related deficienc (50-353/88-15-01)

6.0 Work Observation (Module 52051)

The inspector observed the calibration work done on reactor water clean I up (RWCU) instrumentation. The licensee technicians calibrated RWCU

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Discharge flow transmitter FT-44-2N0120 according to Testing and Labora-

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tories Division procedure TL-11-00307 Revision 1. The inspector reviewed the procedure and the test results on the calibration sheet. The test

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results were within the acceptance value and the test instruments utilized were within calibration. The inspector noticed that procedural steps 6. to 6.2.10 were not performed during the calibration. These steps address the torquing requirements that are required to provide the environmental seal for the subject transmitter The NRC resident inspector also

)- observed this problem and will address it in Inspection Report l No. 50-352/88-1 l The inspector reviewed the calibration of Rosemount trip units model 510DV and 710 DU. Calibration included the testing of the instrument j gross failure indication. The calibration was done in accordance with the manufacturer's manual and the as-left setpoints were within the acceptance value. The licensee is currently J.ilizi4a typical procedures i with a calibration data sheet to perform calibratisn of Rosemount

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Transmitters and trip units. .As there are no system interactions in the current stage of the plant, this approach is acceptable.

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No discrepancies were observe .0 Inspector Followup on Previously Identified Item (Closed) Unresolved Item (87-11-10) This item deals with the wiring deficiencies in the Standby Liquid Control- system (SLCS). The licensee reviewed Startup Deficiency Report No. 135 and was found to be not report-

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able, however,.the inspector had some concerns on the evaluation and the extent of the problem. A later inspection (88-05) requested elementary diagrams and details on other related logic problem The inspector reviewed the elementary drawings, the Startup Field Report No. 8031 and related records to conclude if the defect was significan The wiring was deficient in that the Standby liquid control pump 'C' and the corresponding squib valve would not have performed its safety function. However, this problem was limited to only pump C. The design basis for Limerick station require only one SLCS pump to bring.the reactor c to a shut down. Another redundant ~ pump was operable and .it was the third pump that would have failed if the above deficiency was not corrected. As the deficiency was limited'to the third SLCS pump which was outside the design basis of the Limerick stations, the inspector concurs with the licensee conclusion that this defect was not significant and therefore not reportabl This item is close . Exit Interview At the conclusion of the inspection on June 10, 1988, the inspector met

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with the licensee representatives, denoted in Section 1,0. The inspector

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summarized the scope and findings of the inspection at that time. No written material was given to the licensee during this inspection.

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