ML20215K815

Insp Rept 50-352/87-08 on 870310-12.No Violations Noted. Major Areas Inspected:Emergency Operating Procedures

ML20215K815
Person / Time
Site:	Limerick
Issue date:	04/23/1987
From:	Blumberg N, Bongarra J, Jarrell D, Anthony Mendiola, Myers L, Petrone C Battelle Memorial Institute, PACIFIC NORTHWEST NATION, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), Office of Nuclear Reactor Regulation
To:
Shared Package
ML20215K806	List: ML20215K805 ML20215K815
References
50-352-87-08, 50-352-87-8, NUDOCS 8705110373
Download: ML20215K815 (10)

Text

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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 50-352/87-08 Docket No. 50-352 License No. NPF Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Limerick Generating Station, Unit No. 1 Inspection At: Limerick, Pennsylvania Inspection Conducted: March 10-12, 1987 Inspectors: d[d /2 D. Jarrell, Senior Engineer, Battelle 4/> J// 7 date Pacific Northwest Laboratories (PNL) b h~ h L.- Myers, Sevlor Engineer, Battelle

'tb WJ 7 date Pacific Northwest Laboratories (PNL) 0 h A. Mendiola,(operating License Examiner, NRR b-< .

Ab' date

f. f.x) ~ /m J. Bongarra, Erf41neering Psychologist, NRR Wi$69 date d 4 V/ 7 C. Petrone, Lead Reactor Engineer date Approved by: ,h [M --- -/ r h N. Blumberg/ Acting Chief, Operational 'date Programs Section, Division of Reactor Sa fety .-

Inspection Summary: Inspection on March 10-12, 1987 (Inspection Report Number 50-352/87-08)

Areas Inspected: Special, announced inspection of emergency operating procedures by one region based inspector, two engineering specialists from NRR, and two NRC engineering consultants.

Results: No violations were identified. The licensee's Emergency Operating Procedures were well written and met the commitments specified in their Procedure Generation Package submitted to, and approved by, NRR.

0705110373 870505 PDR ADOCK 05000352 G PDR

DETAILS 1.0 Persons Contacted Philadelphia Electric Company

• J. Franz Plant Manager

• J. Doering Superintendent Operations

'J. Armstrong Assistant Operations Engineer

• W. Rekito Regulatory Engineer (Bechtel)

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

• S. Kucharski Resident Inspector

• N. Blumberg Acting Chief, Operational Programs Section

• J. Johnson Acting Chief, Operations Branch

• Denotes those present at the exit meeting on March 12, 1987.

2.0 Emergency Operating Procedures The Emergency Operating Procedures at Limerick are called TRIP Proced, ,s.

They were prepared in accordance with a Procedures Generation Package (PGP) which was submitted to NRR for review as required by Generic Letter 82-33, " Requirements For Emergency Response Capability" (Supplement 1 to NUREG-0737). The PGP, which was approved by NRR, consists of the following four parts:

Plant-Specific Technical Guidelines (P-STG) which are comprised of the NRR approved Generic Technical Guidelines (GTG) (BWR Owners Group Guidelines) and a list of potentially safety significant deviations from the GTG's with a justification for each; A Plant-Specific Writers Guide (P-SWG) which details the specific methods to be used by the licensee in preparing their TRIP procedures (EOP's);

A description of the program for verification and validation of the TRIP procedures; and, A description of the program for training operators on the use of TRIP procedures.

The purpose of this inspection was to verify that the TRIP procedures had been prepared in accordance with the GTG and the P-SWG, verified and validated as required, and that operators had been trained in their use.

2 2.1 Documents Reviewed:

A-94, Preparation of Transient Response Implementation Plan (TRIP) Procedures; Technical Specifications Section 6.8, Procedures and Programs; NUREG-0737, Supplement 1; T-99, Post Scram Restoration, Rev. 1, 3/5/86; T-100, Scram, Rev. 1, 3/5/86; T-101, Reactor Control, Rev. 1, 3/5/86; T-102, Containment Control, Rev. 1, 3/5/86; T-111, Level Restoration, Rev. 1, 3/5/86; T-112, Emergency Blowdown, Rev. 1, 3/5/86; T-113, Blowdown Cooling, Rev. 1, 3/5/86;.

T-114, Spray Cooling, Rev. 1, 3/5/86; T-115, Alternate Shutdown Cooling, Rev. 1, 3/5/86; T-116, RPV' Flooding, Rev. 1, 3/5/86; and, T-117, Level / Power Control, Rev. 1, 3/5/86.

2.2 Observations and Findings 2.2.1 The inspectors reviewed the records of the licensees' submittal of their PGP and verified that it had been reviewed and approved by NRR in a Supplemental Safety Evaluation Report.

2.2.2 The inspectors reviewed Revision 2 of the GTG (the BWR Owners Group Guidelines) against the licensee's index of plant-specific TRIP procedures .(EOP's) and verified that all procedures specified in the GTG had been issued.

2.2.3 The inspectors reviewed the TRIP procedures for technical adequacy and observed the following:

2.2.3.1 Procedures T101, T102, T111, T112, T116, and T117 were reviewed against the Generic Technical Guidelines (GTG) and the bases documentation which was submitted by the licensee to NRR as

l .

3 part of the PGP. This review, which involved a detailed ' step by step review for technical adequacy, concluded that the TRIP procedures had been prepared in accordance with the GTG.

However, differences between the licensee's pro-cedures and the GTG were identified. These dif-ferences appear to be minor, and, in some cases, is due to the specific plant configuration at Limerick. In other cases steps were identified which should be clarified. Specific comments for each trip procedure are listed in Attachment 1.

The licensee agreed to review these specific comments and, if appropriate, revise their TRIP procedures. These changes will be made as part of their Revision 3 which the licensee plans to complete by September 1987. This revision was already planned by the licensee to upgrade the TRIP procedures to meet. the latest revision of the BWR Owners Group Guidelines. Completion of this revision and NRC Region I review of the above identified items is an inspector followup item (50-352/87-08-01).

2.2.3.2 During these reviews the inspectors also noted that the Bases documentation, which is part of the PGP, was not maintained as a controlled document and was not being maintained up_to date.

This document is used as a reference for training, and a copy is kept in the control room for information. Following discussions with the inspector, the licensee's management agreed to update and control this document to ensure it contained the latest information. The licensee plans to complete this as part of Revision 3 to the TRIP procedures scheduled for September 1987.

This is an inspector followup item (50-352/87-08-02).

2.2.3.3 During the above reviews the inspectors noted that the licensees' Plant Specific Writers Guide (A-94), which is part of the PGP, does not include all the latest recommendations contained in NUREG- 899, " Guidelines for the Preparation of Emergency Operating Procedures." Even though the PGP had been approved by NRR, the licensee agreed to re-review NUREG-899 and, if necessary, update the PGP as part of a future Revision 4 to the TRIP procedures. This is an inspector followup item (50-352/87-08-03).

7 4

2.2.3.4 The inspectors reviewed the safety significant deviations from the GTG and verified they had been reported and justified in the licensee's PGP submittal. No additional safety significant deviations were. made by the licensee subsequent to the original submittal. The inspectors also verified that these deviations, cited in the Supplemental Safety Evaluation, had -been incorporated satisfactorily in the TRIP Procedures.

2.2.3.5 The inspectors selected a sample of five plant-specific setpoint values and verified they had been incorporated correctly in the licensees' trip procedures.

2.2.4 The inspectors reviewed procedures T-99 through T-117 and verified that they had been prepared in accordance with the guidance in the licensees' plant-specific writers guide (P-SWG), A-94, " Preparation of. Transient Response Implementation Plan (Trip) Procedures," Rev. 3. The inspectors also compared the current version (Rev. 3) of A-94 with an earlier version (Rev. 1), submitted as part of the PGP, and concluded that only minor changes had been made. The Revision 3 version currently in use is essentially identical to the version approved by NRR. The inspectors also noted that the licensee is not required to re-submit each revision to NRR for approval.

2.2.5 The inspectors reviewed the steps taken by the licensee to ensure that the TRIP procedures had been . verified and validated as specified in their PGP. Based on reviews of records and discussions with licensee personnel, the inspectors concluded the licensee had complied with their commitments. However, the following observations were i noted.

2.2.5.1 The verification of the last revision to the TRIP procedures had been performed by a single person rather than a mul ti-disciplinary team.

2.2.5.2 The validation was performed at the simulator using a training class performing a variety of scenarios. Not all steps in all E0P's were necessarily validated since the intent of the simulator scenarios was to complete the assigned training. Validation of the Trip procedures was not the primary goal of the simulator exercises.

In addition, the training crew was slightly

5 larger than the minimum size crew. The validation was intended to verify the adequacy of the TRIP procedures to. safely shutdown and cooldown the plant using the minimum assigned Crew.

At the exit meeting the inspector discussed these observations with licensee management. .The licensee. stated that although the final verification had been performed by a single person, other plant staff members had reviewed the procedures in various stages of preparation.

The licensee's management did agree that the verification and validation of the next planned revision (Revision 4) of the TRIP procedures would be performed by a multi-disciplinary team.

They also agreed to ensure that all TRIP procedure steps would be validated on the simulator to the maximum extent possible consider.ing the physical limitations of the-simulator. This is an inspector followup item (50-352/87-08-04).

2.2.6 The inspector observed the licensee-administered operator requalification examinations conducted on the Limerick simulator on March 10, 1987. These exam--

inations involved the use of Limerick's TRIP Procedures by the operators in response to simulator drills. The inspector observed the examination of two-crews, one in the morning and one in the afternoon, to evaluate the quality of the TRIP procedures. The following were noted:

(a) Operators appeared to be familiar with their responsibilities and required actions during an emergency once they determined that an emergency did exist. There seemed to be some confusion about when to enter the TRIP procedures.

(b) The TRIP procedures could be performed by the minimum staff identified in the facility Technical Specifications.

(c) Operators did not physically interfere with each other while performing the Trip procedures.

(d) Operators did sometimes duplicate effort, apparently due to crew confusion and counter-manding orders from supervisors.

(e) Transitions from one TRIP Procedure to another TRIP- procedure, or to other procedures were performed by the operators. During these transitions, it appeared that some of the prerequisites and initial conditions were not met or performed satisfactorily when entering a new procedure. Some operators were not knowledgeable about where to enter and exit some of the procedures.

Based on these observations and the reviews of the TRIP procedures discussed elsewhere in this report, the TRIP procedures themselves appear to be well written, clear, and meet the regulatory guidelines. The performance of the operators during requalification is still undergoing review and - evaluation by Region I license examiners.

The results of this review will be discussed in Inspection Report 50-352/87-07.

2.3 Summary Limerick was one of the first utilities to submit a PGP to. NRR for approval. The E0Ps developed from this PGP were well written, verified and validated. During this inspection, a comprehensive review identified a list of specific observations and recommendations which the licensee has agreed to review and where appropriate, incorporate in their next planned revision of the E0Ps. The E0Ps as written are technically acceptable; the specific observations and recommendations are suggested improvements.

Some of these improvements result from changes that occurred in the years since the Limerick PGP was approved. The inspectors noted the licensee's strong commitment to continually refine and improve their E0Ps by updating them to meet the latest BWR Owners Group Guidelines.

3.0 Exit Meeting The inspectors presented their findings to the licensee's management at a meeting on March 13, 1986.

No written material was given to the licensee at any time during the inspection.

1

- s:

ATTACHMENT 1

. The following specific observations and recommendations were identified during the inspectors review of TRIP procedures discussed in paragraph 2.2.3.1 of this report:

T-101 a) There is no requirement listed to re-enter the beginning of the procedure if a new entry condition develops.

b) Differences exist between the entry setpoints (numbers) listed in the GTG, bases, and the TRIP procedures. (The numbers listed in the TRIP procedures do, however, agree with the numbers in the Technical Specifications.)

c) Some of the cautions contained in the GTG have been included in the TRIP procedures as notes. This appears to lessen the impact of the information. No explanation for these . changes was included in -the bases.

d) Cautions _21, 27, and 34 appear to contain the type of information that should be action statements, not cautions.

e) References to Reactor Pressure Vessel (RPV) level are not consistent.

Inches, level Number L1, L2, etc. , and descriptive phrases (e.g.,

lo lo level) are used in various places.

f) Step RC/P-9 should be clarified. OSDC should be replaced with MFPT.-

g) No specific entry point from step RC/L-10 is listed on T-111.

h) The entry conditions specify a reactor pressure vessel level of -38" rather than the low level' scram setpoint-(+12" at Limerick) specified in the GTG.

1) Procedure RC/L should direct operators to T-117.

j) Steps RC/P-9 and RC/P-10 are in a different order than in the GTG.

k) The RC/P procedure does not discuss rapid depressurization as outlined in the GTG.

1) The RC/P procedure does not contain a caution that a cool down rate of greater than 100* F/hr may be required in certain scenarios.

m) The RC/P procedure does not contain exit criteria to enter an alternate shutdown cooling contingency.

n) The " Exit RC/Q" arrows should direct the operators to procedures T-100/T-99 for recovery.

o) RC/Q-6 reads "Is power below 4%" while the GTG specifies "Is power above 4% or unknown."

G' i

ATTACHMENT 1 T-102

.a) Caution Notes 18 and 34 appear to be action statements, b) The logic flow of step DW/P-19 appears to end abruptly with no way out.

c) Steps SP/T-14 and SP/T-17 should be revised to direct operators to-step SP/T-5.

d) Step SP/T-22 requires emergency depressurization following a "No answer" while the GTG indicates the emergency depressurization should be performed following a "No answer" to SP/T-19.

e) Step DW/T-4 does not include the instruction to " operate available drywell cooling" specified in the GTG.

f) The guidance regarding actual RPV water level contained in Caution  ;

and Note No. 16 is not as explicit as that contained in Caution No. 6 of the GTG.

g) A "No answer" to Step DW/T-7 should direct the operators to enter the T-112 procedure.

T-111 a) Step LR-4 is included later in the procedure than specified in the GTG.

b) Step II-1 states "HPIC ja: RCIC injecting" while the GTG states "HPIC and RCIC injecting."

c) Steps DHI-3 through DHI-9 are not as clearly stated in the procedure as in the GTG.

T-112 a) The basis document refers to a Torus rather than a Suppression Pool.

b) Step EB-11 needs to be revised either by deleting the use of MFPT or by adding a caution to line up for recirculation mode rather than vessel injection. The concern is that the dilution of the injected Boron and addition of cold water might add enough positive reactivity to cause a re-criticality. A similar caution is appropriately contained in T-116, Caution No. 4.

c) Tha GTG indicates that Step EB-5 should be between Steps EB-10 and EB-11.

r..,

o ATTACHMENT 1

~T-116 a) Step RF-22 has a line which ends abruptly indicating ' a possible missing. Step.

b) Steps . RF-2 and - 3, which allows the operators to open three or more SRV's (up to 14) appears to be inconsistent with steps RF-6 through RF-9 which limit the operators to five SRV's maximum.

T-117 a) Steps LQ-2 and LQ-4 specify a high drywell scram setpoint of 4.5 psig in lieu of the 1.68 psig specified in the GTG.