IR 05000352/1987016

Insp Rept 50-352/87-16 on 870615-26.No Violations or Deviations Noted.Major Areas Inspected:Licensee Actions on Previous Insp Findings,Maint Program,Surveillance & Preventive Maint Testing & QC Interfaces

ML20236L739
Person / Time
Site:	Limerick
Issue date:	08/05/1987
From:	Blumberg N, Chaudhary S, Finkel A, Winters R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236L714	List: IR 05000352/1987016 ML20236L711
References
50-352-87-16, NUDOCS 8708100343
Download: ML20236L739 (12)

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! U.S. NUCLEAR REGULATORY COMMISSION l REGION I Report N /87-16 Docket N License N NPF-39 Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Limerick Generating Station Unit 1 Inspection At: Limerick, Pennsylvania Inspection Conducted: June 15-26, 1987 Inspectors: -

A. Finkel, Ledd Reactor Engineer c17 [/77 st(

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/t If97 S. ChauddaYy, Lead Reactor Engineer b/_ fe @ It ! nu

. Winters,' Reactor ngineer

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Approved by: x __ OA-dumberg , L'hief,' _ Operational Programs 8/8/67 date i Section, OB, DR Inspection Summa _ry: A routine unannounced inspection conducted on June 15-26,1987, (Report No. 50-352/87-16)

Areas Inspected: Routine, unannounced inspection of licensee actions on previous inspection findings, maintenance program, surveillance and preventive maintenance testing, and quality control interface Results: No violations or deviations were identifie k[ G DD

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DETAILS 1.0 Persons Contacted Philadelphia Electric Company

• J. Brozonis, Quality Control Engineer  !

• G. Edwards, Technical Engineer i

• C, Edries, Administrative Engineer

• J. Franz, Plant Manager

• C, Harmon, Quality Assurance Engineer

• J. Mc Elwarn, Lead Auditor

• D. Neff, Compliance Engineer

• J. Rabert, Site Quality Assurance

• W. Texter, Superintendent Engineering Maintenance

• C. Wyler, Maintenance Engineer 1 i

United States Nuclear Regulatory Commission l G. Kelly, Senior Resident Inspector S. Kucharski, Resident Inspector

• Denotes those present at the exit meeting on June 26, 1987.

.In addition to the above, inspectors contacted, and held discussions with other licensee personnel (including engineers, supervisors, craft and control room operators).

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2.0 Licensee Actions on Previous Open Items .

(0 pen) Licensee Condition 2.C.10; Modification No. MDCP-106: This license condition required the licensee to provide automatic and diverse isolation signals to reactor enclosure cooling water (RECW) inboard and outboard isolation valves, and drywell chilled water (DCW) outboard isolation valve air supply and return line The inspector verified that the licensee has completed the modificatio This item, however, remains open pending the post modification testing and acceptability of the modification wor (0 pen) Licensee Condition 2.C.11; Modification No. MDCP-0034: This license condition required the licensee to install and test an additional automatic isolation valves in each of the hydrogen recombiner lines penetrating the primary containmen The inspector verified the installation of additional valve in each lin The modification, however, remains open pending the testing, and final acceptance of the wor I i

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a (0 pen) Violation 84-27-04 (Licensee Condition Attachment 1.2.a): This violation pertained to unsealed instrument cable entries in high humidity area The inspector verified that the licensee has completed seal installation in the train 'A' of the ESW line in the pipe tunnel are The seals used for this purpose are "Patel" seals made of stainless st. eel materials. The design and installation of the seals appears to be acceptable. However, the item remains open pending the installation and acceptance of work in the train 'B' of the ESW system (Closed) Follow Item (85-16-04): Analysis of LERs Describing Previous Occurrence The inspector reviewed LERs written subsequent to 85-23 and determined that the licensee has included an analysis of previous events in these LERs. This item is close (Closed) Unresolved Item (85-30-03): Control of Drywell temperatur The inspector reviewed modification design change packages (MDCP) 0732, Addition of drywell chilled water system balancing valves, temperature elements, gate valves and vents, and MDCP 0733, " Pipe Hanger Clamps and Rods Insulation in the Drywell," and observed that the installation of the insulation on the pipe hanger and clamps had been completed. Modification of the chilled water system was in process during the present refueling outage. This item is close (Closed) Unresolved Item (85-36-02): Flood Barriers and Administrative Controls for Door 5 The inspector reviewed MDCP 0828 and observed that Door 56 had been sealed to provide flood protection for the Unit 1 equipment and floor drain sumps. The door was securely locked, sealed with waterproof caulking, and labeled to prevent inadvertent opening. Administrative controls required that the shift supervision control the key to this doo (Closed) Unresolved Item (86-03-01): Troubleshooting Controls and Digital Voltmeter Calibration.

l On February 10, 1985 the reactor scrammed as a result of a worker perform-ing routine tests in accordance with an established procedure and using a calibrated instrument on the non-safety related Electrohydraulic Control (EHC) System. The inspector verified that the instrument was calibrated and examined by the licensee with no anomalies identified. Procedure A-42, Procedure for Control of Temporary Circuit Alterations (TCA) has been revised to require an engineering review of all TCA' Procedure TL-12-50008 was used to control the use of Measuring and Test Equipmen Subsequent routine tests on the ECH system have not resulted in further anomalies. This item is closed.

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l (Closed) Unresolved Item (86-22-02): Tenporary Circuit Alterations, f 8 The inspector verified that procedure A-47, " Procedure for Control of-Temporary Circuit Alterations (TCA)," ha.c been revised to include tagging requirements and a checklist for all TC Retraining or refresher training in the use of this procedure has been completed. This item is close .0 Maintenance Program

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The inspector reviewed the licensee maintenance programs for this refuel ~

ing outage and during their normal operating mode, to determine whether they met the plant Technical Specifications (TS), regulatory requirements (RG 1.33) commitments in the Final Safety Analysis Report-(FSAR), and industry codes and standards (ANSI N18.7, IEEE 279, 323, 450 and 494).

3.1 Program Review The licensee's maintenance scheduling history,and trending programs are based on a computer program identified as " CHAMPS"; and is administratively controlled by their administrative procedure program. Work is authorized and/or implemented by a " Maintenance Request Form" (MRF). The MRF's are the controlling documents for all work related activities at this sit To ascertain the effectiveness of administrative controls and technical adequacy of maintenance activities authorized via the MRF system, the inspector selected a representative sample of MRF's for detailed review and inspection. The sample consisted of maintenance activities on systems and components that were important.to the safe '

operation of the plant and that were committed to be corrected during this refueling outage. In addition to witnessing the work and testing of the completed task, the inspector interviewed licensee personnel responsible for planning, executing, and supervising these activities to assess their familiarity and understanding of the program and administrative controls imposed by the maintenance program and plant procedures. The MRF's reviewed are listed in Attachment I to this repor .2 Maintenance Request Form (MRF) i The purpose of the maintenance request form (MRF) is to initiate the repair or modification of all "Q" listed systems and components whose failure could result in a reduction of plant capacity. This form can also be used to implement and document modifications to plant systems and equipmen The inspector verified, where applicable, the following criteria in each MRF package listed in attachment _ _ - _ - .

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Required administrative approvals were obtained before initiat-ing the work. In all cases the SR0's were knowledgeable of the MRF work package Approved procedures were used and listed in the work packag Quality control inspection hold points were' listed 'in the pro-cedures and the criteria were listed as defined in their quality control plan for this sit Limiting conditions for operation were met while the component or system was removed from service. The lead technical engineers performing the MRF's were knowledgeable of the TS condition for their tas Functional testing and calibrations, as necessary, were completed before returning the component or system tc servic !

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Corrective and preventive maintenance records were assembled and stored as part of the maintenance histor Acceptance criteria was listed in the procedure and verified during the testing phase of the task, and '

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MR .3 Maintenance Request Forms Implementation (MRFs)

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i The inspector observed that MRFs prepared by the plant operating 1 staff were well prepared. They contained suff1ciently detailed i information to plan, execute and document the requested l maintenanc They included criteria for inspection and acceptance of completed work. At the completion of the job, the MRF packages included a complete record of work performance providing a '

comprehensive maintenance history of the affected item. Also, the Plant Operating Maintenance Procedures, which controlled MRFs, were I well written with detailed instructions and defined quality control l involvemen .I

However, MRF packages prepared by modification construction i organizations were not as detailed as MRFs prepared by operating ~

staf The modification MRFs did not define the work in same level  ;

of detail as were found in the maintenance procedures developed by l Operations Staff. This lack of detail was evident in the MRF package for the pipe size increase to the 'A' RHR motor. In this modification, the existing inlet water pipe to the RHR motor was not considered a part of the work, therefore, the inlet pipe became loose on the motor. This resulted in a cooling water leak during l system test, and damage requiring replacement of the RHR moto j

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i Although, the cooling water inlet pipe was not a part of the modification, the effects of its malfunction from the modification activity were not considere This lack of consideration in the work analysis, and inadequate detail in the procedure planning were the cause of the RHR motor failur It, therefore, appears that work procedures prepared by modification construction organization are not as thorough and detailed as those prepared by Operating Maintenance staff. This concern was discussed with the licensee during this inspection and the licensee plans to review their procedures,.between the two organizations, to assure that the level of detail in site procedures are technically adequate to perform the required tas The licensee, during this inspection, modified the RHR procedure and MRF package to provide addition instructions to the craft personnel prior to work performed on the other RHR motors. The "C" RHR pump was reinspected during this inspection period and appeared to be acceptabl The licensee has agreed to review their maintenance procedures based on RHR "A" motor problem and to resolve the concern expressed by the inspector concerning the different level of detail between the pro-cedures prepared by various licensee organizations which perform maintenance or modification Thir item is considered unresolved pending a review of the licensee progress and results during future NRC inspections. (50-352/87-16-01)

3. Maintenance Request Forms Witnessed by the Inspector The following MRF's were reviewed and testing witnessed by the inspector. In all the examples discussed in the following paragraphs, the inspector verified that the following items were c complied with:

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The MRF's specified the scope of the maintenance task and define the accept / reject criteri '

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Required administrative approvals were obtained before initiating the wor In a few of the MRFs witnessed, the SRO performed system flow valve changes for the testing 5 \ grou The testing group was knowledgeable of the limiting condi-tion for operation and the concerns with the system they were working o Approval procedures were used with the quality control hold points listed in the procedure.

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The personnel performing the test were trained and where a new test personnel were involved the service personnel had them witness the work, but did not allow them to make any adjustment The inspector verified that the measuring and test equip-ment was within the calibration dates and that the range of the equipment met the requirements of the procedure; and

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The inspector verified, with the testing personnel, that after the task was completed the system lineups were returned to the as-found position and verified by the SR . Test Witnessed by the Inspector

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ESW Loop "A" Flow - Balance Surveillance Test This test demonstrated that the ESW Loop "A" system was aligned for maximum system heat load and a flow balance of the system was performed to ensure the equipment passed its design flow criteri The inspector witnessed the test and verified that the requirement- of procedure RT-011-251-0, Revision 0 was complied with. The test result approvals were not completed during this inspection period, but the recorded data appeared to be within the requirements of the RT procedur Division 1 Battery Charger - Surveillance Test

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On June 11, 1987 at 0330, while maintenance was performing l an inspection on the Division 1 125VPC batteries, a failure of the 1A10103 battery charger occurred. The charger supplies power to various safety related equipment including the Reactor Enclosure and Refuel Floor ventila-tion logic causing an isolation to both areas thus causing and ESF actuation. The licensee issued a temporary circuit alteration (TCA) to provide a power supply to the de-ener-gized panels. When the TCA change was completed, the "A" RPS shunt trip coil energized causing one of the RPS power supply breakers to open. This caused an inboard instrument gas valve to isolate and a signal to various containment inboard isolation valves that were already either closed or blocked for maintenance. The isolation signal was re-

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stored, along with the battery charger, and all systems were returned to service. MRF No 870443 was issued to determine and correct the problem with the 1 AID 103 Battery Charger. The problem was isolated to a defective current limit control board MBC-1970-1E in the Battery Charge .

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]i th,e 1A10103 Battery Charger restored to operation. The ,

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failure of the board at this time appears to be random in nature and no generic cordition was identifie The inspector verified tha't the 1A1 battery system was reworked per the above listed MRF's and was tested per the 18 month surveillance test procedure No.HST-4-095-951-1, .

R$ vision 1. The testing of the 1A1 batteryisystem was not ,Y complete during the inspection period, therefore, the tcst

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system was in the prc:.:ess of being repaired similar to the '

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methods described in t.he above reference MRF's. Batteries C and D also show sigis of cell leakage, styrofoam discolo-

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ration and acid deterioration, but'nct as advanced as the l 1A1 and 1B1 battery systems'. The C and P battery systems >

are being monitored by the opestions maintenance organiza-

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/ tion but are not scheduled to b outage. An addition tu the main w(r.ance repaired PM during battery this procedure 1 requiring a six mdnth'.i/ acid deterioration inspection will o be made by the meintyns.nce plant staff to assure that the C&D battery systes r'str.eins operational . The present

battery weekly and quafterly inspection procedures also l 3 verify the condf f, sen o f the battery system N"

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Ths inspector witnessed the testing and re-torquing of power cable terminators and boot cons on the A14 Bu ~

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inspector verified that the procedure d3 fine the torque 4 , t' requiren;ents and that the equipment use:i was within the proceduierangandincalibration. A quality control

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inspcior was vitnessing the torquing of the connections as  ;

required by the maintenance procedure and had verified the J s calibration of the tools prior to thostart of the P . l --

Dier,el Generator Water Heat Exchange - Surveillance Test

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TLiMRF'stoinstallpressuretestconnectdesontheESW l return pipe downstream of each Diesel Generator Water Heat '

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Exchange' was verified by the inspceto,r .ow the A and C diesel only during this inspection perlud. The B and D 4 diesel were not modified during this inspo.ction period, but I are scheduled to be completed darog this catage perio ;lhe inspectompitnessed the flow test and the valve s tting's for the A and C diesels per MRF's #870262 .. .

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Control Room and Remote Shutdown Panels Human Factor Enhancement - Surveillance Test Modification (MRF 814) rearranges various controls and indicators in the control room and remote shutdown panels to improve the man / machine interface. The inspector re-viewed the procedures and the testing of the changes made during this enhancement program. The inspector verified that the handles and meter location were changed to comply with the released drawings and the MRF criteria. Approxi-mately 99% of the sixty page job checklist has been in-spected and verified by the quality control organizatio The inspector verified approximately 50% of the changes made to the control room equipment. The documents reviewed by the inspector are listed in Attachment Safeguard Batteries - Preventative Maintenance Test A leak of the Safeguard Battery covers required a repair of the battery cells, styrofoam seismic spacers and replace-ment and cleaning of the battery stand tie rods due to acid deterioration. The 1A1 battery cells have been re-sealed per MRF #8701717, styrofoam seismic spacer replaced per MRF #8607340, and battery stand and Tie Rod replaced per MRF #860731 No violations or other deviations were identifie .0 Quality Control / Maintenance Interface Review of Limerick Administrative and other governing procedures listed in Attachment 1 and discussions with maintenance, quality assurance and quality control personnel, enabled the inspector to ascertain the role of quality control tnd its effect during the maintenance program. During a maintenance history review by the inspector, the following partial list of quality control responsibilities were used as a guideline to verify quality involvement in the performance of maintenance activities:

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Quality control reviewed and concurred with the maintenance procedure inspection points during pre-maintenance MRF revie Sign-off of completed MRF were made by quality control when required by the maintenance procedure.

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Quality Control performed the final MRF review and documented (' unsatisfactory conditions.

i Under the present licensee structure there are two quality control organizations and it appears that they operate under different guide-lines. An example of one type of problem identified is discussed in the

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RHR problem in paragraph 3.3 of this repor Plant modifications and its Quality Control are under the responsibility of the construction organi-zation of engineering while the maintenance of the plant and its quality control personnel.are under the responsibility of the operating organiza-tion. The licensee stated that.this area will be reviewed as part of the evaluation to be performed concerning unresolved item 87-16-0 No violations or deviations were identifie .0 Training The maintenance and the instrumentation and control (I&C) personnel had their training up-dated, when possible, to limit the impact during this outage perio A review of the personnel performing the.MRF's, discussed in Attachement 1 of this report, had their specific records updated and also received on the job training. Discussions with craft personnel, as well as quality assurance and quality control inspectors indicated they were knowledgeable of the tasks they were performin No violations or deviations were identifie .0 Unresolved Items Unresolved items are matter about which more information is required in order to determine whether they are acceptable, an item of noncompliance, or a deviation. An unresolved item in this report is identified in paragraphs 3.3 and .0 Exit Interview At the conclusion of tne site inspection on June 26, 1987, an exit interview was conducted with the licensee's senier site representatives (denoted in Section 1). .The findings were identified and previous inspection items were discusse At no time during this inspection was written material provided to the licensee by the inspector. Based on the NRC Region I review of this report and discussions' held with licensee representatives during this inspection, it was determined that this report does not contain information subject to 10CRF 2.790 restriction l

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O ATTACHMENT 1 Administrative Procedures Reviewed

• A-14, Revision 4, December 8,1986, Procedure for Control of Plant Modification * Form A-14, Revision 2, November 22, 1985, Instructions for the Preparation of the Modification Proposa * Sheet-A-14, App.5, Revision 2, November 22, 1985, Instructions for the Preparation of the Plant Modification Contro Surveillance Test Procedures Reviewed and Witnessed

No. ST-1-049-100-1, Revision 3, RICI Logic System Functional / Simulated Automatic Actuation. Test Frequency 18 month * No. ST-1-050-101-1, Revision 4, Division 1 ADS Logic System Functional / Simulated Automatic Actuation. Test Frequency 18 month * ST-1-051-101-1, Revision 5, Division 1 RHR (LPC1) LSF/SAA. Test Frequency 18 month * ST-1-001-100-1, Revision 3, Feedwater/ Main Turbine Trip LSF/SA Test Frequency 18 month * ST-1-011-490-1, Revision 1, ESW Valve Leakage Tes Test Frequency 18 month * RT-1-011-252-0, Revision 0, ESW Loop "A" Flow Balanc * ST-6-107-593-1, Revision 0, Daily Surveillance Log During Core Offload Procedur * ST-6-095-913, Revision 5, Division 111, 125 VDC Safeguard Battery Quarterly Inspectio *

ST-6-095-904-1, Revision 7, Division IV, 125 VDC Safeguard Battery Weekly Inspectio Maintenance Request Form Testing Witnessed

• MRF No.8704463 - Division 1 Battery Charge *

MRF No.8607340 - Inspect and Replace Seismic Styrofoam Spacers on Division 1A1 Batter . _ _ _ _ _ _ _ _ _ _ - _

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MRF No.8607312 Insoect and Replace Seismic Tie Rods on Division IA1 Battery Holder * MRF No.8701715 - Inspect and Seal Battery Cell Covers on Division 1A1 Batter *

MRF No.8686228 - Clean Diesel Generator 4KV Switchgear Breaker Cubicle D-1 Modification Work Inspected and/or Test Witnessed

Modification 814 - Rearrange various controls and indicators in the Control Room and Remote Shutdown Panels.

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Drawings Reviewed for Mod.81 Meters on Panel - Drawings 10C654-FSK-M1-PHF10C65 Meters on Panel - Drawings 106654-M-1-H12-P654-C-00 RHR GE180 Meters - Panel 10C601-FSK-M-1-PHF-10C60 Change Control to Pistol Grip Handles-E-283,282,259,367,264,564,250 263,296,344,406,365,354,384,382,385,34 Change Amber Light to White Light-M150-52(3)- Equipment Relocation Drawings.No.T176-001A-04 *

Modification 5133 RHR Pump Compartment Units Coolers Piping Chang Documentation Reviewed for Mod. 513 Spool Installation-Record Mod /MRF513 Field Meld Check Off Lis Filler Metal Receipt Authorizatio Mechanical Construction Package Inde *

Preventive Maintenance Procedures Reviewed (PMP)

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P102-PMP-005-003-Revision 1, February 25, 1985, Installation of Condensate Pump Moto P-101-PMP-006-002-Revision 0, October 26, 1984, Reactor Feedwater Pump Coupling Alignmen PMP-022-001-Revision 0, October 26, 1984, Diesel Driven Fire Pump Replacement Oil and Air Filters and Air Cleaner Oil (00-51).

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PMP-047-001-Revision 0, April 30, 1985, Scram Backup Pilot Air Valve Maintenance SV-1F110A/ PMQ-019-001-Revision 0, June 3, 1985, Diesel Generator Pre-Lube Pump Overhaul P-53 PMC 047-004-Revision 3, May 18, 1987, Inlet and Exhaust Scram Valve Diaphragm Replacemen a