ML20153B391

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Insp Rept 50-352/87-31 on 871211-880125.No Violations Noted. Self-identified Violation Discussed.Major Areas Inspected: Resolution of Outstanding Items,Including Response to NRC Bulletin 87-002 & Walkdown of Emergency Svc Water Sys
ML20153B391
Person / Time
Site: Limerick Constellation icon.png
Issue date: 03/08/1988
From: Linville J, Williams J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20153B359 List:
References
50-352-87-31, IEB-87-002, IEB-87-2, NUDOCS 8803220117
Download: ML20153B391 (37)


See also: IR 05000352/1987031

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 87-31

Docket No.

50-352

License No. NPF-39

Licensee:

Philadelphia Electric Company

2301 Market Street

Philadelphia, Pa 19101

Facility Name:

Limerick Generating Station, Unit 1

Inspection Period: December 11, 1987 - January 25, 1988

Inspectors:

E. M. Kelly, Senior Resident Inspector

L. L. Scholl, Resident Inspector

A. E. Finkel, Reactor Engineer

C. H. Woodard, Reactor Engineer

A. Della Ratta, Safeguards Auditor

Reviewed by:

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Da'e'

gH. Williams,ProjectEngineer

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Approved by:

m s LinviTlWChief,

ects Section 2A

Date'

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Summary:

Rout ne daytime (190 hour0.0022 days <br />0.0528 hours <br />3.141534e-4 weeks <br />7.2295e-5 months <br />

and backshift (10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> including

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weekends) inspections of Unit 1 by the resident inspectors and regional

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specialists consisting of (a) resolution of outstanding items including

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response to NRC Bulletin 87-02 on fasteners; (b) walkdown of the emergency

service water system, plant tours, and observations of maintenance and

surveillance; and (c) review of Licensee Event Reports.

Events followed

included reactor enclosure isolations and a resin injection on December 24.

Meetings attended included routine PORC, and a drug training course.

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No violations were identified; however, a self-identified violation involving

CREFAS operability is discussed in Detail 5.2.2.

Examples where the

licensee's activities are instrumental in the assurance of quality are

discussed in Detail 10, and include RCIC test restoration, RPS power supplies

and fitness for duty training.

We noted your management interest in the potential fire hazard associated with

Fairbanks Morse diesel engine lube oil leakage and your intention to promote

an industry owner's group to address and resolve this issue as discussed in

detail 6.2.

Another potential safety concern requiring management attention

concerns the potential for motor-operated valve overcurrent reversal problems,

initially identified during Unit 1 preoperational testing in July 1983 as

discussed in detail 8.1.

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TABLE OF CONTENTS

Inspection 50-352/87-31

1.0 Principals Contacted...........................................

1

2.0 Followup on NRC

Findings.......................................

1

3.0 Plant Operations... ........

6

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3.1 Summary of Events.......

..... ........................ ..

6

3.2 Operational Safety Verification................

..........

7

3.3 Station Tours.............................................

9

3.4 Safety System Operability......

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4.0 Onsite Followup of Events... ...... ... .......................

10

4.1 Secondary Containment Iso 1ations..........................

10

4.2 Resin Injection and Conductivity Transient.

11

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4.3 SNM Shipment.......................

11

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4.4 Feedwater Level Transient.,

12

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4.5 Worker Injured..... ........ ... . ................ ......

14

5.0 Licensee Reports..................

.............

15

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5.1 In-of fice Review of LER's. . . . . .

15

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5.2 Onsite Followup of LER's. ... . . .. ............. .......

16

5.3 Periodic or Special Reports....

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5.4 Security Event Reports....

20

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6.0 Surveillance Testing......

23

.. ........................ .......

6.1 Test Observation....

23

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6.2 Diesel Exhaust Leakage.............

24

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7.0

Maintenance.......................

28

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7.1 Work Observation..

28

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.... .. .... .......................

7.2 Battery Charger Mal function. . . . . . .

28

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7.3 RCIC Overspeed Trip R3 set...................

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7.4 Diesel Control Switch..

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8.0 Common Unit Issues.

29

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8.1 Valve Overcurrent Reversal.... . .

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8.2 DC MCC Wiring.............

......... .. .

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9.0 Nuclear Review Board Organization.

31

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10.0 Assurance of Quality.

32

....... .. .............

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10.1 Internal Panel Wiring Errors...

32

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10.2 Fitness for Duty Training.

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10.3 RCIC Test Restoration.

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...

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10.4 LER 87-23 Attention to Detail.. .

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13.0 Management Meetings........

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DETAILS

1.0 Principals Contacted

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Philadelphia Electric Company

J. Doering, Superintendent of Operations

R. Dubiel, Senior Health Physicist

G. Leitch, Vice President, Limerick

J. Grimes, Branch Engineer, Testing and Labs

J. Milito, Field Engineering Supervisor

D. Helwig, Manager, Quality Assurance

J. Spencer, Superintendent of Services

E. Sproat, Limerick Project Manager

E. Kistner, Nuclear Review Board Chairman

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R. Scott, Modifications Superintendent

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Also during this inspection period, the inspectors _ discussed plant status

and operations with other supervisors and engineers in the PECO, Bechtel

and General Electric organizations.

2.0 Followup on NRC Findings

2.1 NRC Bulletin No. 87-02; Fastener Testing

In response to NRC Bulletin 87-02 regarding fastener testing, the

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licensee selected a sample of fasteners as required by action number

2 of the bulletin.

The inspectors witnessed the licensee's

selection on December 11 to ensure that a diverse sample of various

grades and sizes were randomly chosen from those in stock.

The

licensee performed chemical and mechanical testing however the test

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results were not available as of the end of the insr.ection period

and will be included in a future inspection report.

During the selection of the fasteners, the inspectors noted that the

Unit 1 storeroom was well-organized with all components clearly

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segregated and storeroom personnel were knowledgeable of procedures.

2.2 (Closed) Unresolved Item 87-05-02: CADD Drawing Errors

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Conversion from manually drafted drawings to a computer aided design

drafting (CADD) system was initiated for Limerick Unit 1 piping and

instrumentation drawings (P& ids) in February 1986.

The CADD

drawings were originally issued on July 18-24, 1986, and drawings

were distributed onsite in August 1986.

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Because of a number of errors discovered between September-December

1986, the licensee issued a Part 21 Report on March 16, 1987,

describing errors introduced in the drawings by the conversion from

the manually drafted drawings to the CADD system. A complete

quality reverification of the CADD generated drawings was completed,

and corrected drawings were in place at Category 1 drawing locations

by March 1987.

To correct the CADD system errors and assure that an effective

verification process is in place, the licensee issued an Engineering

Department Project Instruction (EDPI) No. 4.46.2, on January 8,

1988, titled, "Project Drawings Computer Aided Design and Drafting

(CADD)". The salient point in this procedure is a requirement for a

100's verification of any CADD generated drawing against the original

drawing before returning it to the project.

The licensee's QA organization performed surveillance SCR No.

ILC-100 on January 15, 1988, to verify that the corrective action

taken to correct the CADD problem has been effective.

The

surveillance report concluded that all issues bearing directly on

the quality of CADD produced drawings had been satisfactorily

addressed. An inspection of the present controls, per EDPI 4.46.2,

and a review of selected drawings by the inspector indicated that

the sunmary findings of the licensee's surveillance report No. SCR

ILC-100 were consistent and acceptable.

This item is closed.

2.3 (Closed) Unresolved Item 87-24-01; Rapid Plant Shutdown Procedures

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The licensee revised and issued reactor engineering maneuvering

procedure RE-201 to provide instructions to operators on maintaining

a control sequence during a plant shutdown such that rod worth

minimizer (RWM) and rod sequence control systems (RSCS) will be

automatically latched-in at power levels below the low power

setpoint (22*4 power) without corresponding control rod

withdrawal / insert blocks.

The licensee also revised the RWM pull

sheet to ensure that RSCS Group 10 control rods (targeted deep) are

initially inserted and Group 9 rods (control cell core) are

subsequently inserted to quickly reduce power and maintain sequence.

The procedural changes were approved in PORC meeting 88-008.

This

item is closed.

2.4 (Closed) Violation 87-19-01: As-built Drawing Update

On August 20, 1987, an incorrect revision of electrical drawing E-15

was removed from the control room and the blocking / permit

coordinator's office. On August 21, 1987, the As-Built Drawing

Update form (Appendix 7 to Procedure A-14) was revised to include a

change notice IDCN-006 to drawing E-15.

The redlining was

accomplished, and the drawings were distributed to Category 1

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locations.

In addition, all Category 1 drawings affected by plant

modifications made since a licensee modification audit on April 27,

1987 were reviewed for completeness.

The inspector reviewed the modification coordinator (MC) drawing

location checklist and verified licensee review of five Category 1

areas.

The MC staff audits the Category 1 locations biweekly to

verify current revision of drawings.

In addition, Administrative

Procedure A-14, Appendix 7, has been revised to implement these

changes. A specific time limit has been added to the A-14 procedure

requiring that verification of a modification change within two

working days after the change is received from reproduction. The

inspector, on a selected sampling basis, verified that the MC staff

personnel were performing this task within procedural criteria and

that the MC was performing an independent review of the redlining

process performed by MC personnel.

The inspector also verified that

the MC discussed the problem with responsible personnel and that

proper action was taken to resclve the problem. This item is

considered closed.

2.5 (0 pen) Unresolved Item 87-16-01; Construction Procedure Detail

During a plant piping modification the inlet water pipe to the RHR

oil cooler was inadvertantly loosened allowing cooling water to leak

into the RH9 pump motor. To insure that the Maintenance Request

Forms (MRFs) prepared by the Engineering and Research Department,

Construction Division, consider other areas than their specific

modification work, the licensee has taken the following steps:

Revised "Procedure for Installation of Mechanical Equipment, CD

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5.7".

This procedure has added further guidance for the

Mechanical Site Lead and Construction Engineer as well as

additional planning and quality centrol inspection guidelines.

Procedure CD 5.3 "Procedure for Installation of Electrical

Equipment", was also updated to reflect similar changes as made

in CD 5.7 above.

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Revised procedure for "Preparing Engineering Work Letters and

Construction Division Field Engineering, and Testing and

Laboratories Division Memoranda", ERDP 2.2, Revision 15.

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The licensee has also prepared a check list to be used when

preparing the Construction Job Memorandum (CJM).

The inspector

reviewed two CJMs, Mod. 5133, "RHR Pemp Compartment Unit Cooler

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Piping Change" and Mod. 5029, "Install Cooling Fans on SMVA Site

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Services Transformer".

The procedures reflected subjects discussed

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in the CJM.

Due to licensee organization changes being implemented at this time,

other procedures are being revised which were not reviewed during

this inspection period.

This item therefore remains open.

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2.6 (0 pen) Unresolved Item 85-30-01; Third Offsite Power Sources

The inspector reviewed the status of licensee progress in

implementing plant and procedure changes which would make a third

offsite power source available in the event that one of the two

offsite power sources required by technical specifications is lost.

Two items of concern regarding this power source are physical

independence from the 220 kV offsite source, and the capability to

place the source into service within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Plant modification

961 is being prepared to accomplish the following:

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Install cabling in underground conduit

Refurbish equipment to be used (i.e., spare 33 kV circuit

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breaker)

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Install protective relaying for the circuit breaker.

The use of the underground conduit run is intended to provide

physical independence while the modification work will reduce the

time required to put this source in service upon failure of one of

the other two offsite power sources.

This item remains open pending

implementation of the necessary plant modifications.

2.7 (Closed) Unresolved Item 87-29-01: Station ALARA Review Committee

The inspector attended the Station ALARA Review Committee (SARC)

meeting chaired by the Station Manager on December 18, 1987.

The

meeting was conducted in accordance with Administrative Procedure

A-83 and a proper quorum was present, including first-line

supervision from construction and maintenance groups.

Items

discussed included:

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Station exposure goals for 1988

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The role of management and workers in ALARA

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Specific post-job reviews

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Individual ALARA concerns

The inspector also reviewed Revision 1 to procedure A-83 which was

approved in PORC Meeting 87-130 on December 30.

No unacceptable

conditions were noted, and based on the management support of the

SARC and the revision to A-83, this item was closed.

The inspector discussed proposed changes in SARC philosophy with

station management because of recent licensee reo ganization

activities.

Further NRC review of SARC activities and effectiveness

of the ALARA program will be reviewed in future NRC inspections.

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2.8 (Closed) Inspector Followup Items 87-08-01 thru 04: Emergency

Procedures

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Emergency operating procedures (EOPs) were reviewed in NRC

Inspection 50-352/87-08 for conformance with the BWR Owner's Group

program, specifically the General Technical Guidelines (GTG),

including documentation of bases.

The Limerick. Plant Specific lechnical Guidelines were approved on

January 11, 1988 and were based upon Revision 4 to the GTG.

The

revision clarified or resolved differences (noted during the NRC

inspection) between the Limerick-specific Transient Response

Implementation Trip (TRIP) procedures and the GTG. Also, a revision

to Administrative Procedure A-94, Preparation of TRIP Procedures,

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was approved in PORC Meeting 87-117 on November 24, 1987, to

incorporate comments from NRC Inspection 50-352/87-08, and brought

the Limerick E0P program into full compliance with the GTG,

The inspector reviewed recent revisions to TRIP procedures T-101,

102, 111, 112, 116 and 117.

Revision 2 to each of these procedures

was approved in PORC Meeting 87-117 with minor comments noted, and

were issued for training and use on January 13, 1988.

These TRIP

procedures are in flow chart form for use in the main control room.

The procedure revisions were discussed with the responsible engineers,

operations group supervision, and licensed operators. All were

knowledgeable in the procedural steps changed, most notably on the

concept of re-entry into the TRIP procedures as new entry conditions

are identified.

Another finding from NRC Inspection 50-352/87-08 concerned bases

documentation for the TRIP procedures, which had not been maintained

as a controlled document nor maintained up to date. Since the TRIP

bases are used as a reference for training, and copies are kept in

the main control room for information, the licensee revised

Administrative Procedure A-94 to require controlled TRIP Bases and

issued Revision 0 to all T-101 series documents on December 9,1987.

The licensee also issued new TRIP procedures T-103 and 104 to

implement BWR owner's guidelines on secondary containment control

and radiation release controls.

The inspector reviewed the new

procedures, discussed comments related to T-103 and 104 in PORC

Meeting 87-110 (October 30, 1987) minutes, and ascertained that

verification and validation of the new procedures was performed by a

multi-disciplinary team en the Limerick simulator.

In addition,

Administrative Procedure A-94 was revised to formally require

simulator validation by a multi-disciplinary group for futu 2 TRIP

procedure changes.

Finally, additional comments by the NRC were expressed in a letter

to the licensee dated August 7, 1987 (W. Johnson to J. Gallager)

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concerning inconsistencies in TRIP procedure T-116, Reactor Pressure

Vessel Flooding.

Specifically, the use of safety relief valves

(SRVs) as a vent path out of the top of the vessel or the head vent

or other alternate paths during vessel ficoding were questioned.

The NRC concerns were clarified by the licensee in stating that

there was_never any intention to establish equivalency between vent

methods (i.e., SRVs versus alternate paths) and that, if the

required number of SRVs could not be opened to allow use of the

minimum alternate flood pressure table (contained on the T-116 flow

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chart), then other methods would be pursued.

The inspector had no

further concerns and these items are closed.

2.9 (Closed) Unresolved Item 85-30-05; Generator Brush Arm Stress

A Colt-Fairbanks diesel generator support arm on the rotor slip ring

brushes at Millstone Unit 3 failed by fatigue during preoperational

testing in August 1985.

The similarity in design to the Limerick

generators was reviewed in NRC Inspection 50-352/85-30 and found not

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to be identical. The Limerick. brush support arms are one-half the

length of the Millstone design and, as such, are concluded to be

less susceptible to the fatigue failure. The licensee's Mechanical

Engineering representatives contacted the manufacturer of the

generators, Louis Allis Co., who confirmed that the shorter brush

arm on the Limerick generators has a much higher (eight times)

resonant frequency and that adequate wall thickness exists for the

brush holder assemblies.

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The Millstone failures were stat w to be random, and resulted

from holes drilled too deep for the brush arms.

Evaluation of

Limerick installation drawings and x-ray pictures subsequently

provided by the licensee to Louis Allis showed adequate wall thick-

ness for the Limerick brush arm assemblies.

The Limerick stud

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length of eight and one-half inches was concluded to greatly reduce

structural load factors in that area.

Based on the above, and on licensee QA Audit No. AL 86-41 which

addressed this issue, the item is closed.

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3.0 Plant Operations

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3.1 Summary of Events

Unit 1 operated at full power throughout the inspection period and

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completed 121 consecutive days at power as of January 25, 1988.

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further main turbine electrohydraulic control system vibration

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concerns (the subject of extensive engineering analyses and control

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system modifications following a scram on September 19, 1987) were

experienced in this period.

An injection of resin into feedwater

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occurred on December 24, 1987 while placing a filter demineralizer

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in service (Detail 4.2) causing a conductivity transient and reduced

power operation for four days.

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Several secondary containment isolations occurred (Detail 4.1) due

to cold ambient air conditions and other control system

difficulties. Operating problems with the RCIC overspeed trip

mechanism (Detail 7.3) and emergency diesel engine exhaust (Detail

6.2) were experienced, as was a switch contact problem for the D14

diesel engine local / remote control switch (Detail 7.4).

The NRC issued a Temporary Waiver of Compliance on December 18,

1987, enabling the licensee to begin implementation of organizational

changes announced in November 1987, pending formal licer.se amend-

ments.

Effective January 1, 1988 the Limerick Station Manager was

transferred to Peach Bottom and the Vice President of Limerick Station

assumed the role of acting Station Manager pending training and

indoctrination of an individual selected to become Unit 1 Station

Manager.

3.2 Operational Safety Verification

3.2.1

Control Room Activities

The inspectors toured the control room daily to verify

proper manning, access control, adherence to procedures

and compliance with technical specifications.

The

inspectors reviewed shift superintendent, control room

supervision, and licensed operator logs and records

covering the entire inspection period.

On December 18,

1987 and January 25, 1988, backshif t inspections were

performed between the hours of 2:00 am and 6:00 am.

The inspectors reviewed logs and records for completeness,

abnormal conditions, and significant operating changes and

trends. Other records reviewed included:

reactor

engineer and shif t technical advisor (STA) books, night

orders, radiation work permits, the locked valve log,

maintenance request forms, temporary circuit alterations,

and ignition source control checklists.

The inspectors

also observed shift turnovers during the period.

Operations activities were observed to be in conformance

with Administrative Procedure A-7, Conduct of Plant

Operations.

On minuary 6, a reactor core isolation cooling (RCIC)

system area temperature instrument was found to be

inoperable during a review of Daily Surveillance Log

(ST-6-107-590-1) by shift supervision.

The inoperability

was a result of improper system restoration fol',,<ing

surveillance testing, as discussed in Detail 6.3.

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3.2.2

Security

During entry to and egress from the Unit 1 protected area

and vital areas, the inspecters observed that access

controls, security boundary integrity, search activities,

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escorting and badging were 13 accordance with Security

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Plan implementing procedures and guard force instructions.

The inspectors also observed the availability and

operability of. security systems such as search equipment,

perimeter detection devices, and security computer alarms.

The inspectors verified that the minimum number of armed

guards required by the Security Plan were present on

selected shifts by review of duty rosters, discussion with

licensee Shift Security Advisors, and observation of guard

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force turnovers.

The inspector also reviewed the security procedures for

vehicles access via the North Gate. Post Order Number 7

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was reviewed and discussed with the security force members

on duty. The inspector also observed the search and

entrance of a vehicle into the protected area, as well as

the controls imposed on emergency vehicles which require

immediate plant access. The guards displayed a thorough

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knowledge of their duties as delineated on the post

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orders. No violations were identified.

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3.2.3

Fitness for Duty Investigations

On January 7, 1988, site access was terminated for a Unit

2 Bechtel construction worker when the licensee was made

aware (through police contacts) of his offsite illegal

drug activities.

The individual was interviewed by PECo

security management.

Site security reviewed the personnel

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access records and determined that since the initial

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implementation of the security plan, this individual never

had access to the Limerick Unit 1 protected area.

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On January 8, 1988, plant management informed the resident

inspector that a former Peach Bottom employee, who is

currently being prosecuted for illegal drug activities,

had implicated other Peach Bottom employees as also being

involved in drug activities. Two of the individuals are

currently employed at Limerick and the licensee is con-

tinuing its investigation to determine if the allegation

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is credible.

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3.2.4

Radiological Controls

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The inspectors observed the availability and use of radia-

tion monitoring equipment, including portal monitors and

portable friskers.

The inspectors also observed health

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physics (HP) supervision and technicians in plant

activities involving potentially significant radiological

conditions.

Radiological controls for posted radiation and

contaminated areas were assessed as part of the inspector

review. Radiological conditions were discussed with HP

technicians.

Proper locked high radiation area controls,

including appropriate and frequent surveys, were verified

to be employed.

The inspector had no concerns, and

identified no violations.

3.3 Station Tours

The inspectors toured accessible areas of the plant throughout the

inspection period, including:

the Unit I reactor and

turbine-auxiliary enclosures, the main control and auxiliary

equipment rooms; battery, emergency switchgear and cable spreading

rooms; the spray pond pumphouse; diesel generator cubicles and the

plant site perimeter.

During these tours, observations were made of

potential fire hazards, radiological conditions, housekeeping,

tagging of equipment, ongoing maintenance and surveillance, and the

availability of required equipment.

No unacceptable conditions were identified.

3.4 Safety System Operability

3.4.1

Emergency Service Water

The inspector performed a detailed walkdown of portions of

the emergency service water (ESW) system in order to

independently verify system operability.

The walkdown

included review of the following:

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Technical Specifications 3/4.7.1.2, FSAR Section

9.2.2, P&ID M-11, and Licensed Operator Training

Plan 0680

Inspection of ESW equipment conditions

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System check-off list S11.1.A (Col-1,

-2, -3) and

system operating procedures consistent with plant

drawings

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Valves and switches properly aligned including

appropriate locking devices

Instrumentation properly valved-in and operable

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Satisfactory status of control indicators and

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controls

Surveillance test procedures ST-011-203, 206, and 231

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appropriately completed at the required interval

ESW Loop ' A' and 'B' Flow Balance procedures

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RT-1-011-251 and 252 performed as part of the system

retest following piping modification work

Within the scope of the inspection, no unacceptable

conditions were noted.

The inspectors discussed recent

maintenance, modifications, and design concerns related to

the ESW system with responsible test engineers.

Proper

operation of the ESW System was also v2rified as part of

quarterly pump testing of the system as discussed in

detail 6.1.

No unacceptable conditions were noted.

4.0 Onsite Followup of Events

4.1 Secondary Containment Isolations

During the inspection period, reactor enclosure isolations occurred

on two dates. On December 29, two reactor enclosure isolations were

received within 30 minutes of each other due to low differential

pressure conditions in the secondary containment.

The loss of

building negative pressure occurred when the normal supply and

exhaust ventilation fans tripped on a low supply air temperature due

to extremely cold ambient conditions. A temperature control switch

was found to be defective. An additional set of heating coils was

placed in service and no additional problems were experienced.

On December 31, a reactor enclosure isolation occurred on a low

differential pressure signal which was caused by the tripping of the

reactor enclosure normal ventilation fans.

The ventilation fans

tripped on a low temperature signal but no problems with air

temperature or the heating coils were evident.

The inspectors confirmed proper system response during the

isolations, immediate corrective actions, and appropriate reporting

to the NRC.

No further reactor building isolations occurred from January 1

through the end of the report period, January 25.

The inspectors

will continue to follow corrective actions proposed by the licensee

to resolve ventilation problems.

..

11

.-

4.2 Resin Injection and Conductivity Transient

On December 24, approximately one pound of condensate filter

demineralizer (demin) resin was inadvertently injected into the

reactor vessel.

The injection occurred when 'E' condensate filter

demineralizer was placed in service.

Indications of the injection

were higher than normal main steam line radiation levels, increased

radiation levels at the steam jet air ejector, and a decrease in

reactor coolant pH.

'

The licensee investigation determined that there was no evidence of

failure of the demineralizer filter elements but that the most

likely cause of the injection was resin contamination of the

downstream side of the 'E' filter demineralizer elements during a

previous regeneration cycle.

Reactor coolant conductivity increased to a maximum of 3.62

micro-mhos per centimeter, and pH dropped to 5.42.

Both parameters

were restored to technical specification limits within six hours and

therefore no special actions were required.

The inspector verified

that the licensee has a program to monitor cumulative time of

operation with increased coolant conductivity levels. This time is

recorded in procedure RT-5-041-875-1.

Procedure changes were issued to filter-demineralizer regeneration

operating procedures to prevent the use of an improper drain path.

The licensee also developed a videotape training session which is

intended to reduce instances of personnel error.

This training was

a result of a special PORC meeting to review recent instances of

personnel error and possible corrective actions.

The inspector had

no further concerns.

4.3 Special Nuclear Material (SNM) Shipment

On December 9, 1987, the licensee shipped two packages to the

Commonwealth Edison Company's LaSalle County Nuclear Station. The

packages reportedly contained two fission counters, each containing

one gram of 93% enriched uranium. On December 14, 1987, the

licensee received a telephone call from a LaSalle Station

.

representative notifying the licensee that, upon receipt inspection

l

of the fission chamber shipping packages, the two fission chambers

'

containing the enriched uranium were not in the packages.

The

licensee immediately conducted a search of the fuel floor area where

the packaging was performed and found the fission chambers in a

yellow contamination control bag.

The fission chambers had been

inadvertently left out of the shipping packages,

i

l

l

t

I

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_

_-

.-

- _ _

- .

.__-

_-

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12

The licensee's reactor engineer staff conducted an investigation and

presented a report to the PORC for evaluation on December 18.

Based

on the licensee's preliminary findings, the following changes were

initiated for incorporation in Administrative Procedure A-44:

-

The Reactor Engineeer shall have responsibility for arranging

the packaging and shipment of SNM.

QC shall verify the packaging of all SNM for shipment.

-

-

All fission chambers checked out of the storeroom will be

tagged with highly visible tags that identify the items as

SNM until the item is installed, returned to the storeroom or

shipped.

The inspector had no further concerns, and identified no violations.

The controls for SNM will be reviewed in future NRC inspections.

4.4 Feedwater Level Transient

The inspector reviewed Upset Report (UR)-034 prepared by the

operations staff and reviewed and issued by the PORC on January 14,

1988.

The report covered a reactor water level transient due to a

less of feedwater control power that occurred on November 19, 1987,

and was followed-up and documented in detail 4.2 of NRC Inspection

Report 50-352/87-28.

The UR contained a detailed sequence of events for the

transient, an analysis of selected equipment failures and associated

plant response, and three distinct recommendations. Also attached

to the UR, and reviewed by the inspector, were feedwater control

logic diagrams, strip chart records, selected emergency display

system plots and process computer alarm typer printout.

The inspector discussed the immediate operator response to the

transient with licensed personnel on shift at the time of the

transient.

The reactor operator quickly recognized a feedwater

control circuit failure and took manual control and began feed pump

turbine runbacks within 20 seconds by reducing motor speed changer

settings.

Reactor vessel level increased to +52.8 inches in 23

seconds (one inch below the high level main turbine trip setting

which would have resulted in a reactor scram) before the combination

of an automatic reactor recirculation pump runback and the

operator's actions stopped the level increase.

A rapid level

decrease was then experienced which reached a minimum of +18.4

inches in 43 seconds (six inches above the scram setpoint) before

additional operator actions to increase feed pump speeds terminated

the water level drop.

Operator manual control of reactor water level was then complicated

by several factors during the next four to six minutes.

The 'A'

feed pump was running at low flow, but with no minimum flow

protection because its recirculation line had been previously

..

.

_ - . - .

.

_

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_ _ -

_ _ - _ _ - - _ _

__

_- __ _ _ _ _ _ _ _ . _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ ___ -

13

.

'

,

-1

l

isolated because of leakage.

The 'A' pump was therefore. tripped in

five_ minutes. -The 'C' feed pump turbine speed had been originally

locked-in at 3690 rpm and continued to feed at a mass flow rate of

approximately 3.9 million 1b/hr.

However, because flow indication

had been lost, the reactor operator thought that the 'C' pump was not

feeding and tripped the pump five and one half minutes into the

transient. This caused another rapid water level decrease from a

normal condition of +34 inches to a minimum of +18.0 inches before

the reactor operator took manual control of the 'B' feed pump (the

only pump feeding at this point) to again terminate the level drop.

Normal reactor vessel level was stabilized in 12 minutes by

reopening the ' A' feed pump miriimum flow line and increasing speed

of the 'A'

and 'B'

pumps.

- Attempts to insert control rods (to increase thermal margins) were

prevented by RWM insert blocks caused by a loss of steam flow

indication and a resultant false low power setpoint condition.

Reactor power remained at approximately 57% with reactor

recirculation pump speed at the 28% limiter setting. Approximately

one hour after initiation of the transient, operators had identified

the cause of the failures to be an inadvertantly opened circuit

breaker in nonsafety related panel 10Y201. An additional

,

!

complication arose when the open circuit was re-energized which

caused both reactor recirculation pumps to increase speed.

'A'

loop

,

flow increased from 6,000 to 16,750 gpm and 'B' loop flow increased

from 7,500 to 21,000 gpm.

The additional flow caused power to

increase to the APRM upscale alarm, but remained below the 75% flow

limiter setting at which a high flux scram may have occurred.

>

Recirculation pump speeds were then manually dacreased and adjusted

to develop a core flow of 50%. With the RWM no longer enforcing

after restoration of the open control circuit, a symmetrical rod

pattern was established, process computer thermal limit calculations

were obtained and were verified to be within limits.

Normal reactor

water level was m;intained with the two operating feed pumps.

The cause of the transient was the inadvertant de-energization of

circuit 11 in electrical panel 10Y201 oy a nonlicensed operator

whose hand had slipped while attempting to open an adjacent

,

auxiliary boiler circuit brecker in the same panel. The effect of

.

the loss of circuit 11, which powered various nonsafety-related

J

circuits, included:

1

i

Loss of 'C' feed pump flow indication (downscale) and lockup of

--

the turbine motor gear unit.

-

Feedwater master controller failure upscale, causing the 'A'

and 'B' feed pumps to increase speed and flow.

Reactor vessel

i

level correspondingly increased and reactor power increased

'

from 85 to 89% in 16 seconds,

l

4

1

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,

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.-

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,- - , . , , . . . , .

, - , _ . , _ _ _ . , . , , , - , , , , _ - . . - . _ - , , , - . , - - -

.

.

.

.

.

.

.

.-.

.

.

5

,

,

14

,

Reactor recirculation pump automatic runback to 28% rated speed

-

occurred, reducing power to 45% in 18 seconds. The runback was

due to the loss of circuit 11 power to feedwater flow summer

C32-K615 whose output dropped below 20% of rated feedwater flow

for greater than a 15 second time delay.

-

Steam flow / feed flow indication power was lost and, because-

-

sensed steam flow indication dropped below 20%, the rod worth

minimizer (RWM) began enforcing control rod insert and withdraw

blocks.

An important feature of the reactor recirculation pump runback

circuitry was later identified as part of the post-transient review.

The automatic reset of the runback logic (such as occurred when

circuit 11 was re-energized) can result in an unexpected increase in

pump speed when a low feedwater flow condition clears. The

increased pump speed returns to the value that the manual controller

had been demanding.

In this event, the shift superintendent had

recognized this automatic reset feature and had directed that the

,

'

manual controllers'be reduced to below the 28% speed limiter. The

controller demands were subsequently reduced by the reactor operator

'

but not to a setting below the limiter.

The licensee prepared a

request to engineering (EPE-1191) on December 1, 1987 for modifi-

cation of the runback logic.

Seal-in of the speed limitation on low

feedwater flow, thereby requiring a manual reset, will prevent the

possibility of high flux scrams by eliminating the automatic reset of

the recirculation pump runback logic and will simplify transient

response and recovery.

The inspector concluded that the investigation conducted by

operations as documented in UR-034 was thorough and that

recommendations for improved breaker blocking techniques would be

adequately tracked as PORC commitments from PORC meeting 88-01. No

further concerns were identified.

i

4.5 Worker Injured in Decontamination Tank

On January 16, at approximately 9:30 a.m., a contractor became

unconscious and stopped breathing while working in a decontamination

tank.

The worker was immediately discovered by a health physics

technician who successfully administered cardiopulmonary

resuscitation (CPR). The worker stopped breathing a second time and

again was revived.

The individual regained consciousness and was

(

transported to the Pottstown Memorial Hospital where he was examined

and released by noon the same day.

The worker was not contaminated.

'

The worker was employed by Bartlett Nuclear Inc. and was attempting

to clean a drain in a 4'x4'x8' decontamination tank (located in a

-

trailer outside of the Radwaste Enclosure) which had been used two

l

to three days earlier.

However, the lower section of the tank still

contained an atmosphere of freon that had not been fully purged.

,

r

i

i

- ~ - -

-

o

15

..

The licensee has stopped further high pressure freon decontamination

activities and is alerting the industry of this potential generic

safety concern.

5.0 Licensee Report

5.1

In-Office Review of Licensee Event Reports

The inspector reviewed Unit 1 LERs submitted to the NRC Region I

office to verify that details of the event were clearly reported,

including the accuracy of the description of the cause and the

adequacy of the corrective action. Where multiple causes are

suspected, or may be different than reported in the LER, this is

,

indicated below.

The inspector determined whethei further

information was required from the licensee, whether generic

implications were involved, and whether the event warranted on-site

followup. The following LERs were reviewed:

LER Number

and Date

Subject

Root Cause

85-74

Valve isolations

Blown fuses

Revision 1

1/15/88

87-23

Battery charger

Failed electronics

Revision 1

f r.i l u re

12/10/87

87-48

EHC pressure loss and

EHC control system

Revision 1

reactor scram

instabilities

1/5/88

87-49

Startup of recircula-

Incorrect temperature

Revision 1

tion pump without

reference in test

12/3/87

verifying temperatures

procedure

87-61

CREFAS inoperability

Licensed operator error and

12/16/87

for 1 1/2 hours

inadequate procedure

87-62

Secondary containment

Nonlicensed operator error

12/21/87

isolation and initia-

in using A&C exhaust fan

tion of SGTS and RERS

combination

87-63

Fire suppression water

Licensed operator error

12/24/87

header isolation

in failing to adhere to

administrative proceduros

.__ _

- _. -

- - _____ __ _____

3

16

. . .

87-64

Secondary containment

Auxiliary boiler trip and

12/21/87

isolation and SGTS/RERS loss of auxiliary heating

initiation

steam to supply fans

87-65

Secondary containment

Low intet air temperature

12/21/87

isolation and SGTS/RERS trip of normal ventilation

I

initiation

supply fans

87-66

HPCI Overspeed Trip

Blockage of drain port in

1/7/88

Malfunction

reset mechanism

'

The events described in LER Nos. 87-62, 64 and 65 were previously

addressed in Detail 4 of Inspection Report 50-352/87-28, and

corrective actions are addressed in Detail 5.2.1 of this report.

LER 87-61 is addressed in Detail 5.2.2 and LER 87-66 is addressed in

Detail 5.2.3.

LER No. 87-63 is addressed in Detail 3.2.1 of

Inspection Report No. 50-352/87-28.

The inspector noted that three.LER's during this inspection period

(LER Nos. 87-61, 62 and 63) were submitted late by an average of

eight days beyond the 30-day requirement. While not a concern for

the quality and accuracy of the reports, this lateness suggests a

management inadequacy in planning and compiling pertinent data and

enlisting appropriate support among various organizations and work

groups involved in the events reported.

These comments were

discussed with the Limerick Licensing Engineer and at the exit

meeting for this report.

5.2 Onsite Followup of Licensee Event Reports

For those LERs selected for onsite followup, the inspector verified

that the reporting requirements of 10 CFR 50.73 and the Technical

Specifications had been met, that appropriate corrective action had

been taken, that the event was appropriately reviewed by the

licensee, and that continued operation of facility was conducted in

accordance with technical specification limits.

5.2.1

LER Nos. 87-62, 64 and 65; Reactor Enclosure Isolations

As a result of the ongoing problem with reactor enclosure

isolations, the licensee has accomplished the following:

the normal reactor building ventilation supply fan

-

low temperature trip function was taken out of

service, using a temporary circuit alteration to

prevent spurious actuaticns. Air inlet temperature is

monitored by plant operators when outside air

+emperature is below 35 degrees F.

.

_

>

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17

.-

the importance of notifying control room personnel

-

before changing equipment operating lineups was

stressed to all operating personnel in turnover

meetings and by shift night orders.

investigation of the inability of the 'A'

and 'C'

fan

-

lineup to maintain adequate negative pressure in

the secondary containment is continuing, An Operator

Aid has been posted to warn operators of the problem

with using this fan combination.

an engineering evaluation is being performed to

-

review several methods of improving the reliability

of the auxiliary boilers.

The status of this review

is to be reported to the Nuclear Review Board (NRB)

at the next scheduled meeting. Also, the Test

Engineering Group prcvided some additional guidance to

shift supervision on how to operate the boilers to

improve reliability under varying steam demand

conditions.

The inspectors will continue to follow these issues.

5.2.2

LER 87-61; CREFAS Inoperability

LER 87-61 described the inoperability of both trains of

control room emergency fresh air supply (CREFAS) for

approximately three and one half hours on November 7,

1987, because of the lack of an available return flow

path. The loss of a flow path was the result of operators

placing the CREFAS return fan operating switches in the

off position because of previous overcurrent trips of the

fans.

The fan trips resulted after operators had entered

Off-Normal procedure ON-115, Loss of Control Enclosure

Cooling, following failure of the 'A' control enclosure

chiller due to a faulty relay.

The 'B' chiller was

out of service for maintenance at the time. After one

hour without control enclosure cooling, and as directed by

procedure ON-115, operators placed control and auxiliary

equipment room ventilation systems in a simultaneous purge

mode of operation to maintain room temperatures below 78

degrees F.

However, the control room ventilation return

fans then tripped (15 minutes after beginning purge

operation) on overcurrent conditions because purging both

spaces (control and auxiliary equipment rooms)

simultaneously is outside of the design capacity of the

duct.

The return fan breakers were reset and, to

prevent further fan trips and potential damage, the

- .-

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18

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1

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control switches were placed in the off position.

Purging

was continued for the next three hours by opening control

room doors for an exhaust path.

Operators were unaware that'CREFAS operability required

,

automatic fan control switch positions, since CREFAS

.

initiation will terminate any purge operational alignment

'

(and the one in which the return fans were experiencing

tripping).

Recurrent return fan trips would have been

experienced with the control switches left in automatic.

.The fans remained available for manual operation during

'

the three and one half hours in which CREFAS was

inoperable. After this time, shift supervision discussed

.

the operational problems experienced during purge

operation with station management and concluded that-

-

continued operation with the return fan operating switches

in an off position did not meet technical specification

requirements for CREFAS operability (i.e. toxic gas or

.

radiation initiating conditions).

The inspector verified

that control room temperatures remained below 78 degrees

,

during subsequent purge operations. The 'A' chiller was

'

e

returned to service, following relay replacement,

!

approximately 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> after cooling was lost.

'

The licensee issued a memorandum to shift personnel and

revised procedure ON-115 on November 10, 1987, containing

appropriate instructions on purge operation. At PORC

meeting number 88-02 held on January 22, 1988, control

room ventilation operability questions were discussed

,

including ON-115 instructions, purge operation and

!

attendant concerns for electronic equipment reliability at

increased temperature conditions.

The PORC recommended

engineering analysis of CREFAS initiation response times

and isolation functions during purge operation when a

-

chiller is not available.

I

The inspector concluded that no violation would be issued

for this licensee-identified problem (50-352/87-31-01)

'

since it existed for a relatively short time and was a

>

'

unique operational problem that has not been recurrent,

i

j

Appropriate reporting and corrective actions were

!

accomplished. The inspector had no further concerns.

1

i

5.2.3

LER No.87-66; HPCI Overspeed Trip Malfunction

i

Licensee Event Report 87-66 reported the inoperability of

the High Pressure Coolant Injection (HPCI) system due to

l

,

'

l

erratic operation of the HPCI turbine stop valve during

surveillance testing.

During the test, the hydraulic

.

mechanical overspeed trip mechanism cycled between the

l

l

tripped and normal positions, causing the turbine stop

l

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..

19

.

'

valve to close and open several times.

The cause was a

blockage of an internal port in the overspeed trip reset

'

plunger assembly which subsequently cleared during

operation of the auxiliary oil pump.

The overspeed trips

could not be duplicated following the initial occurrence.

The HPCI turbine lube oil was sampled for particulates and

found acceptable.

The HPCI pump and turbine were operated

for 100 minutes during the performance of the quarterly

flow test (ST-6-055-340-1), with no recurrence of the

problem. The licensee also has increased the operating

time of the auxiliary oil pump during the performance of

the monthly HPCI turbine overspeed trip check

(RT-1-055-330-1) in an attempt to reproduce the problem.

No repeat problems have occurred.

The licensee is tracking this problem by use of the Plant

Incident Tracking (PIT) System as Item No. 87-12,

5.2.4

LER No. 87-48, (Revision 1); Scram Due to EHC Weld Failure

The licensee revised LER 87-48 to describe adjustments to

the electrohydraulic control (EHC) system steamline

resonance compensator to remove signal oscillations

experienced because of a modification to change from full

arc to partial-arc turbine steam admission.

The EHC fluid

pressure loss which resulted in a September 19, 1987 scram

was concluded to be vibration-induced failure of an

improperly bonded weld, and therefore an isolated event.

All other EHC welds were inspected visually and with dye

penetrant and no evidence of cracking was found,

A modified steamline resonance compensator (SLRC) was

installed which effectively removed the control signal

oscillations at power levels above 80% as reported in NRC

Inspection 50-352/87-28.

Full power operation was

achieved by November 21, 1987.

The temporary circuit

alteration (TCA) which enabled installation of a second

resonance compensator in the 'A' channel regulator is

planned to be made into perrcanent modification number

87-5731.

The inspector observed the on-line installation

of the new resonance compensation filters, reviewed the

safety evaluation for the modification, and based upon

stable servo-currents for the main turbine control valves

over the past two months concluded that the 2.55 Hertz

third harmonic frequency of the main steam lines was

eliminated.

._

_ _ _ .

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20

  • *

The inspector also reviewed other associated concerns with

turbine partial-are admission operation as outlined in a

corporate engineering memorandum to the Limerick Station

Manager (PM0M-1502) dated December 7,1987. The concerns

"

are for turbine control valve opening setpoints, waterhammer

potential and operation with control valve number 3 against

the open stop.--Although LER 87-48 did not discuss these

additional concerns, the inspector noted that steps are

'

being taken to pursue modifications to correct the problems

at the next Unit 1 outage.

5.3 Periodic or Special Reports

Periodic or_ special reports submitted by the licensee were reviewed

by the inspector.

The reports were reviewed for the required

information, that results and/or supporting information were

l

i

consistent with design predictions and performance specifications,

and whether any information in the report should be classified as an

abnormal occurrence.

l

The following reports were reviewed:

Monthly operating report for December 1987

--

PECO letter to NRC (Fogarty to Russell) dated November 30,

--

1987; Summary Reports for ISI and ASME Repairs

PECO letter to NRC (Gallagher to Lazarus) dated December 23,

--

1987; Objectives of April 1988 Emergency Exercise

1

,

Annual Report of Plant Modifications (Alden to Russell) dated

--

December 8, 1987

Cycle 2 Startup Report (Alden to Russell) dated November 24,

'

--

1987

<

Annual Report of Safety Valve Challenges dated January 7, 1988

--

The inspector had no questions about the reports.

.

5.4 Security Event Reports

The inspector reviewed the following reports made by the licensee in

accordance with the security requirements of 10 CFR Section 73.71.

i

Details of the reports were withheld from public disclosure as

1

i

safeguards or confidential information.

{

I

Report 87-503 dated December 7, 1987

--

Report 87-504 dated January 5,1988

--

The details were found to be accurate, appropriately reported and

4

contained appropriate corrective actions.

Followup of the reports

i

l

will be pursued in future NRC Regional security specialist

i

inspections. No violations were identified,

.

.1

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21

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5.5 Part 21 Reports

The following reports made under 10 CFR Part 21 were reviewed by the

inspectors for accuracy, corrective action and progress of

resolution.

5.5.1

Brown Boveri Undervoltage Relays

The manufacturer of an undervoltage (UV) relay used for

the reactor protection system power supply breakers

reported a potential for misoperation to the NRC in a

letter dated December 22, 1987. Brown Eoveri Model 27N

relays (Catalog No. 211T4175-HF) with a harmonic filter

were identified to be susceptible to spurious trips when

DC control voltage is reapplied after having been off for

a period of time.

Relay diodes under this condition

became reverse-biased (in an off state), unstabilized, and

depending upon wiring configuration are capable of

coupling a small amount of the AC input signal being

monitored.

The coupling induced allows partial

energization of certain integrated circuits within the

relay, causing them to experience indeterminant states.

When the DC coil voltage is restored, the relay circuits

do not consistently power-up in a nornal fashion, and a

false trip signal is generated in about 30 milliseconds.

Following another 30 milliseconds, the trip condition

clears.

The licensee discovered the spurious tripping as part of

followup testing described in Revision 1 to LER 87-23.

The failure of the UV relay occurred when the Division 1

battery charger was lost which resulted in a loss of DC

coil power.

Subsequent re-energization of the coil caused

the 'A' channel RPS power supply breaker to open.

The

unexplained tripping of the breaker by the UV relay

was subsequently resolved by site testing of three spare

UV relays modified with the harmonic distortion module.

Each relay was tested 100 times (i.e. DC coil power

removed and then re-energized) with the following results:

Relay

% of failures (trips when re-energized)

1

none

2

30%

3

50%

The licensee sent the relays to the manufacturer for

more testing to confirm the design problem with the

relays.

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The inspectors verified that the spurious trips of RPS

'

breakers by UV relays do not pose an operational safety

concern since the failure is safe and occurs only upon loss

of and restoration of DC coil power. The licensee committed

.

to a supplement to LER 87-23 to update the status of

replacement of the UV relays.

The inspector had no further

concerns.

5.5.2

Containment Penetration Overcurrent Protection

!

On August 14, 1987 the licensee notified the NRC per 10 CFR Part 21 that redundant overcurrent protective devices

were not provided for several conductors that pass through

,

primary containment penetrations.

This requirement for a

second circuit breaker was identified in design

,

calculations, but was not later embodied in all design and

f

construction documents resulting in only single protection

5

on several penetrations.

.

,

Plant design modification 5573 was implemented during the

first refuel outage to provide N d up overcurrent

i.

protection for the affected circuits. The inspector had

'

'

no further questions on this item.

5.5.3

Post-LOCA Radiation Monitor Cable Resistance

,

!

The manufacturer of the Unit 1 po n-accident radiation

'

monitors, General Atomic (GA) Technologies, Inc., reported

!

a deficiency in the Rockbestos cable insulation resistance

,

at elevated temperatures for the subject moritors

,

installed in the drywell. The deficiency was reported to

'

the NRC on February 23, 1987 under 10 CFR Part 21. The

i

monitor's signal coaxial cable located inside primary

[

containment and supplied by Sorrento Electronics (a

i

'

subsidiary of GA), was found to have insufficient

,

insulation resistance (three megohms per 1000 lineal feet)

-

.

at elevated temperatures.

NRC Regulatory Guide 1.97

'

!

accuracy requirements specify a minimum cable insulation

resistance of 500 megohms.

j

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The licensee evaluated the four Unit 1 monitor configurations

'

and, using the longest cable run, analyzed the worst-case

error introduced for post-accident condition radiation

monitor readings because of high leakage current due to

cable dielectric losses.

In a memorandum to the Limerick

Station Manager from Electrical Engineering dated August

t

17, 1987, the results of design analysis number 5506 were

l

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presented which indicated the following:

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The worst case error caused by signal cable leakage

-

current is 31%

-

The Limerick Emergency Plan Alert setpoint for

post-accident containment radiation levels is 100

rad / hour; a 31% error at high temperature would be

within the required factor of two accuracy

At temperatures below 340 degrees but above 245

-

degrees,"the error introduced is less than 30%.

Below 245 degrees, the -nnired accuracy is

-

maintained in all cas

monitor indications are

valid for all radiati.

1es.

Based on the conclusions o

- > analysis, the licensee

justified continued operativa with the monitors until the

cable could be replaced during the next outage. Operator

Aid 26-24 was approved by the PORC and issued on August

20, 1987 at main control room panel number 10C600.

TM

aid graphically depit.ts the conditions under which

containment radiation readings may be invalid (i.e.

ce

radiation fields up to 35 rad / hour conincident with

drywell temperatures between 240 and 340 degrees F). The

inspectors noted that these conditions would not be

theoretically expected to be present except for the

initial two to ten minutes of a design basis event

(reference FSAR Section 6.2).

The inspector had no further questions.

6.0 Surveillance Testino

6.1 Test Observations

The inspector observed the performance or reviewed the results of

the following tests:

ST-3-107-790-1; Control Rod Scram Timing

--

ST-6-107-590-1; Daily Surveillance Log

--

ST-6-011-203-0; 'A'

Loop ESW Valve Test

--

ST-6-011-206-0; 'B'

Loop ESW Valve Test

--

ST-2-049-613-1; Nuclear Steam Supply Division 1 Functional

--

--

ST-6-092-311-1; Monthly D-11 Diesel Run

ST-6-011-231-0; Loop A ESW Pump, Valve and Flow Test

--

The tests were observed to determine that surveillance procedures

conformed with technical specification requirements; testing was being

performed in accordance with Administrative Procedures A-43 and 47;

proper administrative controls and tagouts were obtained prior to

testing; testing was performed by qualified personnel in accordance

with approved procedures and calibrated instrumentation; test data

and results were accurate and withir, techn' cal specification limits;

and equipment was properly returned to service following testing.

.

24

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No unacceptable conditions were noted.

6.2 Diesel Exhaust Leakage

The inspector witnessed the licensee's conduct of the monthly

surveillance test for the D-11 emergency diesel generator.

Successful conduct of this test includes:

pre-lube of the engine

for two to three minutes; starting and reaching rated speed and

voltage within ten seconds after the cranking cycle is initiated;

and then loading the generator to at least rated load in no more

than 200 seconds after synchronizing with the grid.

Engine

operation is then continued at rated load for not less than one

hour.

6.2.1

Initial Condition

Prior to conducting the test the engine was inspected for

evidence of oil leakage at the flanges of the transition

piping section from the engine exhaust gas lines to their

respective turbochargers since oil seepage from the

flanges has caused smoke in the diesel cubicles when the

exhaust lines become hot.

Routine smoke alarms from diesel

exhaust manifcid leakage when an engine is initially started

were stated to be a concern since these could mask a true

fire smoke alarm.

There have never been any actual fires

in diesel cubicles at Unit 1.

The exhaust flanges showed evidence of oil darpness on the

engine side but no accumulation of oil was evident.

There

was no evidence of oil on the engine except for some minor

amounts of oil in the engine cy Mcder galley in the

vicinity of the fuel injectors.

This was considered

normal.

6.2.2

Engine Operation

During the pre-lube cycle and prior to engine start, there

was no evidence of oil. Within the first minute of

starting the engine, oil leakage began at the lower

transition flange and continued at a rate of approximately

one drop per second for about five minutes.

The flanges

on the opposite side showed no evidence of leaking;

however, the upper flange was covered with loose asbestos

wrap.

Small amounts of oil were observed to drop from the

air start distributor onto the turbocharger piping.

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During this time the exhaust piping began to get hot and

the-oil at the flanges and on the exhaust piping began to

smoke' heavily.

The exhaust piping reaches temperatures of

up to 900 degrees F.

Leakage from le flanges stopped

within about ten minutes of engine operation. - Large

-amounts of oil vaporized from both sides of the engine

during the first five to ten minutes of loaded operation.

After about 15 minutes of operation the smoking stopped,

when all of the oil in the exhaust line had evaperated or

was being :onsumed within the exhaust.

6.2.3

Smoke Ef fects and Fire Hazard

The licensee routinely experiences smoke alarms from the

diesel oil leakage.

TSe smoke in the diesel cubicle

created a hazy cloud throughout the room.

The inspector

confirmed that the pre-lube pump came on, as demanded, and

also shut off properly such that pre-lube was discontinued

automatically along with an engine start.

The inspector noted substantial oil leakage in the hot

manifold area (in the vicinity of the Woodward Governor and

the cylinder galley) could cause a fire.

6.2.4

Vendor Recommendations

The inspector reviewed the manufacturer's operating

instruction manual and operating instructions. Operating

Procedure S-92.1.0 was reviewed and the inspector found

t ht.

in all matters relating to pre-lube, starting,

running, loading and unloading of the diesel, the

licensee's procedures were in agreement with the

manufacturer's recommendations.

6.2.5

Engine Repairs

Because of the oil leakage from the exhaust line, the

licensee elected to replace the gasket. All bolts were

verified to have been torqued properly in the previous

installation.

There are two bolts holding each of the

four-inch flanged exhaust lines to the manifold.

Each

exhaust line is four to eight feet long, with a built-in

expansion bellows.

The pipes are curved to provide for

fit-up from the cylinder exhausts to the turbocharger

manifold.

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The pipe with the leaking flange was removed and

approximately one-half pint of lube oil was found in the

piping.

Examination of both the pipe and manifold flanges

showed about a three-inch arc length where the leak had

occurred.

The gasket showed obvious evidence of crushing.

in the arc area where the leak occurred.

The licensee's analysis of the gasket failure will. include

the amount of force (against the gasket) to ensure proper

bolt torque. When the exhaust pipe heats up from ambient

to operating temperature it expands, causing additional

pressure on the gasket (in spite of the bellows

compression). The pressure would be uniform all around

the flange and gasket if the force on the pipe were

perpendicular to the flange / gasket face. However, the

configuration of these exhaust lines appear to cause the

force to be concentrated on one side of the gasket which

would eventually destroy the gasket and permit leakage.

~

The other section of exhaust pipe was removed and no

evidence of leakage or gasket damage was evident.

The

section of the exhaust pipe was angled from the cylinder

exhaust and did not have any oil accumulation. Upstream

of the connecting piping, there was approximately one inch

of oil accumulation.

6.2.6

Conclusions

It appears that, during engine shutdown, lubricating oil

from the upper crankshaft accumulates at the cylinders

(between the pistons) and then below to the exhaust lines

where it lays until it either weeps out through the

gaskets or until the engine is.run again and it burns out.

Lube oil in the exhaust line would not be a problem if itL

did not weep out since after the engine exhaust heats up

the lube oil is burned away.

The licensee is considering manually turning-over the engine

or air-rolling it after shutdown, such that the lubricating

oil pumped to the upper engine is drained to the crankcase

rather than being allowed to stand in the upper engine and

drain into the exhaust manifold.

The problem is applicable

to the Fairbanks Morse opposed piston design and is not

unique to Limerick.

The licensee is initiating the formation

of a Fairbanks Horse nuclear diesel owners' group and has

proposed addressing the issue of exhaust manifold flange

leakage. This item is unresolved pending resolution of the

exhaust leakage problem at the turbocharger inlet flanges

(50-352/87-31-02).

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6.3 Improper RCIC Restoration

The inspector reviewed the circumstances which resulted in a

violation of technical specifications which require that inoperable

isolation actuation instruments be placed in the trip condition

within one hour. On January 15, an instrument and control (I&C)

technician performed surveillance test ST-2-049-613-1 which, in

part, functionally tests the Reactor Core Isolation Cooling (RCIC)

system pipe routing area high temperature isolation instrumentation.

During restoration from this test, thermocouple leads were

terminated incorrectly (the positive and negative leads were

reversed) and an independent verification also failed to identify

this condition.

On the two shifts following the I&C surveillance test, the

operations personnel recognized a change in the indicated

temperature for the affected instrument during the performance of

the daily surveillance log, procedure ST-6-107-590-1.

The

instrument continued to provide an on-scale indication, however,

with the leads reversed, the temperature reading was approximately

30 degrees lower than actual area temperature.

The third shift

questioned the change in the temperature reading and initiated

troubleshooting which discovered and corrected the thermocouple

leads.

Test procedure ST-2-049-613-1 was reviewed and found to have

adequate directions for restoration and verification of the leads

which are lifted to perform the test.

The cause of the occurrence

appears to have been inattention to detail on the part of the I&C

technicians.

The independent verification of restoration program at

Limerick has been good in the past, and this appears to be an

isolated incident.

The daily surveillance log is utilized to perform instrument channel

checks. A channel check is the qualitative assessment of channel

behavior during operation by observation; however, specific

quantitative acceptanc e criteria are not provided in the procedure.

The inspectors concluded that additional guidance in the procedure

would be beneficial to the operators, and allow an easier and more

reliable comparison of similar readings when attempting to determine

t

equipment operability during the performance of a channel check.

The licensee is evaluating other utility methods and procedures used

to accomplish channel checks.

The inspectors will review the

proposed corrective action for this issue in LER No. 88-01.

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7.0 Maintenance

The inspector observed selected maintenance activities on safety related

equipment to ascertain that:

the work was conducted in accordance with

Administrative Procedures A-25, 26 and 27 using r.pproved work

instructions or. procedures; proper equipment permits and tagging were

applied; craft performing the work were appropriately qualified and

supported; and return-to-service of equipment included adequate

post-maintenance testing and operational verification.

7.1 Work Observation

Portions of the following work activities were observed or reviewed:

--

MRF No. 8701102; HPCI Turbine Lube Oil and Filter Change

--

MRF No. 8780076; HPCI Lube Oil System Inspection

--

PMQ No. 056-022; HPCI 011 Tank Clean and Refill

PMQ No. 056-028; HPCI Lube Oil Filter Replacement

--

No unacceptable conditions were noted.

7.2 Battery Charger Malfunction

During observation of maintenance repairs to the Division 3 battery

ch&rger on December 4, 1987 reported in NRC Inspection Report

50-352/87-28, the inspector discussed the potential use of a spare

charger should battery inoperability exceed eight hours.

Limerick

FSAR Section 8.3.2 describes two spare battery chargers which are

provided to replace any of the Class 1E chargers as direct

replacements.

The spare chargers are briefly noted in the FSAR description of DC

system independence, as addressed by NRC Regulatory Guide 1.6,

'

because there are no design provisions for transferring loads

between redundant DC systems.

The inspector noted that, in an

argument similar to the potential use of a third offsite AC power

source (refer to NRC unresolved item 85-30-01), the use of a spare

charger as a qualified DC power source should involve consideration

of seismic, security, fire and other design issues.

The licensee

developed a request to engineering on January 7, 1988 to redesign an

existing modification (number 412) which will install a spare

400-amp charger for DC channels A and B, and a spare 75-amp charger

.for DC channels C and D.

The requested redesign will evaluate

seismic mounting, channel separation and AC supply independence.

The inspector had no further concerns.

7.3 RCIC Overspeed Trip Reset

During the performance of RCIC turbine trip test, ST-2-050-606-1, on

January 20, the turbine trip could not be reset.

Test engineering

investigation revealed that the overspeed '. rip mechanism had

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actuated.

The trip was reset, however, during efforts to repeat the

incident, trip / throttle valve HV-50-112 could not be remotely reset

from the control room and had to be manually closed locally.

This was the result of a worn component on the trip / throttle valve.

As of the end of the inspection period, maintenance engineers were

developing a repair method.

The suspected cause of the initial overspeed trip is that the trip

mechanism linkage may have traveled a portion of the way towards the

trip position (possibly as a result of being bumped by someone

working in the area).

The subsequent mechanical. shock associated

with the electrical trip caused the mechanical overspeed trip

linkage to fully activate.

7.4 Diesel Control Switch

During the performance of the weekly diesel D-14 surveillance test

ST-6-092-314-1 on January 19 a. lack of governor control was

.

experienced from the main control room.

The D-14 engine was

'

declared inoperable pending an engineering evaluation.

The test was

satisfactorily completed after the contacts were cleaned on the

multi-contact local / remote switch.

On January 22, temporary circuit

alteration (TCA)-1234 was applied to ensure governor control from

the control room pending switch replacement. However, if local

governor control was required the TCA would have to be removed.

Therefore, a change to the safe shutdown procedure SE-8, Appendix D,

was issued which directs removal of this TCA if this safe shutdown

methed is needed. An operator aid was posted at the local / remote

switch to reference the change to SE-8 should it become necessary to

i

remove the TCA.

8.0 Common Unit Issues

'

The inspectors addressed the following issues for applicability and

effect upon Unit 1.

The issues were identified by either NRC or licensee

inspections of Unit 2.

The issues include potential significant

!

construction deficiences currently under review for Unit 2.

The

inspectors ascertained that:

the licensee's QA programs are addressing

,

Unit 1 applicability; Unit 1 station management and operating staff are

!

aware of the potential concerns; and the safety significance and proposed

resolution are appropriately determined.

8.1 Valve Overcurrent Reversal

!

The inspector reviewed Unit l's potential significant deficiency

report (SDR) number 85 identified in September 1983 by the licensee

but subsequently determined to be not reportable on January 3, 1984.

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The deficiency was associated with preoperational testing of motor

operated valves (M0V's) in the reactor water cleanup (RWCU) system.

The RWCU MOVs being tested were containment isolation valves which,

when travelling in the open direction when an automatic closure

signal was simulated, tripped and failed in a partially open

condition.

The failure was a result of the instantaneous reversal

which overrides the open signal and causes a high current that trips

the 480 volt circuit breaker feeding the valve operator. The

licensee's conclusion that this defic!ency was not significant was

based on a redundant isolation valve 11 series with the affected

MOV, and on the low probability that both valves would be opened

simultaneously. While not considered reportable, the licensee did

replace the RWCU isolation valve breakers with a larger breaker and

changed breaker overcurrent settings to twice the locked-rotor

current of the motors.

RWCU valves HV44-1F001 and 004 have 7.8 HP

-

motors which normally draw 11.4 full-load amps and have locked-rotor

ratings of 94.3 amperes.

The adjustable circuit breaker overcurrent

settings were changed to 190 amps and the adjustments were

documented on Startup Field Report Nos. 61A-13 and 41 approved on

April 30, 1984.

The Startup Field Reports suggested that the ramifications of the

overcu,' rent reversal problem be evaluated for other high speea

isolation valves. While that recommendation was addressed for the

other RWCU valves, the licensee could not confirm whether or not the

issue was expanded to include other Unit 1 isolation-valves.

The inspector discussed the issue of overcurrent trip of MOV's with

,

the Limerick Project Manager and Supervising Field Engineer.

Selected Unit 1 MOV data for the locked rotor current and actual

,

breaker instantaneous overcurrent settings were being made available

at the end of the inspection period.

This item 1s unresolved

pending further review (50-352/87-31-03).

8.2 DC Motor Control Centers

The licensee reported a potential Unit 2 significant construction

deficiency to the NRC Region I office on January 22, 1988.

Internal

wiring on three direct current (DC) motor control centers (MCC's)

was found to be different from the Westinghouse wiring diagrams.

The licensee corrected a number of wiring errors during Unit 1

preoperational testing (specifically ' blue-tag' testing).

The

inspector reviewed selected field modification control (FMC)

packages and Unit 1 Rework Notices for DC equipment, and concluded

that the problem, while not reported as a Unit 1 construction

deficiency, nad been recognized and corrected prior to Unit 1

operation which began in December 1984.

In fact, because of the

'

Unit 1 DC MCC experiences, the subject potentiai Unit 2 deficiency

was initiated. Also, because of the relative simplicity and limited

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number of DC MCC circuits, the wiring errors were easier to identify

and correct than analogous AC wiring errors.

The inspector had no

further concerns, and identified no violations.

9.0 Nuclecr Review Board Organization

The Nuclear Review Board (NRB) is organized as an independent advisory

group dealing with reactor safety at the licensee's nuclear stations.

The NRB reports to a Senior Vice President on a regular basis and to the

Office of the Chief Executive Offi.:er on a quarterly basis, as a minimum.

In addition, the Chairman of the NRB meets directly with the Chairman of

the Nuclear Committee of the Board of Directors (NCB) and reports to the

Board at least once annually.

The inspector noted that the licensee's Nuclear Review Board charter

(Revision 10) was recently revised.

To support NRB activities, the

licensee has issued the following NRB procedures:

-

NRB-1, Review Practice

NRB-2, Determination of an Unreviewed Safety Question

-

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NRB-3, Audits

NRB-4, Teleconferencing

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NRB-5, Use of Consultants

The inspector reviewed those procedures and selected the following NRB

meeting notes for evaluation:

-

No. 8302L, Plant Manager's Report

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No. 8415L, Report on Radiation Protection

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No. 8414L, Special Items

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No. 8507L, Review of OEAC Minutes

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No. 8403L, Review of Item List

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No. 8501L, PORC Review

'

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No. 8506L, Current Licensing Issues

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No. 8701L, Review of Licensee Event Reports

No. 8702L, Review of Violations

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No. 8413L, Quality Assurance

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No. 8505L, Review of Safety Evaluation

I

The inspector selected meeting notes 8501L, 8201L and 8702L for detailed

l

review.

The reports were well written.

It appears that the NRB members

posed in-depth questions to arrive at the stated conclusions.

Items that

require further action are documented in an open items status list which

is maintained by the NRB Chairman's assistant.

This list is planned to

!

be added to a computer tracking system in the near future.

!

l-

NRB agenda items and the results of NRB meetings appear to be well

documented, with historical data available.

The NRB Audit Program for

l

1988 is presently in a management review cycle and was not available

j

during this inspection period.

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The inspector had no further questions at this time.

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10.0 Assurance of Quality

This area of evaluation, recently added to the NRC's Systematic

Assessment of Licensee Performance (SALP) process, assesses activities at

all leveh of the licensee's organization that are integral in assuring

the quality of Unit 1 operation.

Inspection findings that are notable

examples wherein quality work is being either maintained or hampered, as

found in previous details of this inspection report, are summarized

below.

10.1 hternal Panel Wiring Errors

The licensee completed an inspection of the remainder of the Power

Generation Control Complex (PGCC) panels after an initial inspection

had identified several deficiencies in which inactive leads were not

properly insulated and secured.

The initial inspaction was

parformed to determine if any miswirings, similar to those

ident1fied on Unit 2, were present in the Unit 1 panels.

The li.;ensee's latest inspection was expanded to include 1352

connections and identified minor discrepancies.

However, no actual

incorrect wirings have been found during Unit 1 inspections.

NRC

Inspectio- n'oort 50-352/87-28 had stated that the wiring problems

in the Unis > PGCC panels were identified on August 31; however, a

review of records indicates the findings actually occurred on

September 23, 1987.

Changes have been made to the Temporary Circuit Alteration (TCA) and

Troubleshooting Control Form (TCF) procedures, A-41.1 and A-42, to

add caution and sign-off steps which ensure all available

documentation (i.e. wiring diagrams and schematics) as well visual

inspect.,ns of as-built wiring configurations are used to identify

any labeling discrepancies prior to implementing the TCA on the TCF.

The licensee has not made a determination on what further actions

will be taken to resolve the wire labeling problems which were

identified on Unit 1.

The item is being tracked as a PORC

commitment and the inspectors will follow the licensee's resolution

in a future inspection.

10.2 Fitness for Duty Training

The inspector observed a portion of an Industrial Substance Abuse

Supervisory Awareness Program which was presented to Bechtel Company

supervisors.

fhe training was presented by a consultant under

contract to PECo. A wide range of topics were covered including the

physical effects of drugs and alcohol on the body, how to recognize

individuals using drugs or alcohol, and how to proceed if you

suspect a worker is coming to work under the influence of drugs or

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alcohol. A demonstration of dogs trained in drug detection was also

given.

The drug dogs were onsite to perfcrm a sweep of the Unit 1

and 2 areas as a method of detecting and deterring onsite drug.use

or possession.

These actions demonstrate an aggressive, multifaceted program

designed to eliminate onsite drug use at Limerick.

10.3 RCIC Test Restoration

As discussed in Detail 6.3, there was an apparent breakdown in the

independent verification of restoration procedures during the

performance of a RCIC surveillance test.

Proper system restorations

are an important quality attribute and, although this has not been a

recurrent problem, the verification was not adequately performed.

It is noted that the licensee's policy is to avoid lifting leads

wherever possible but the inspector also noted minimal, if any,

Quality Control involvement in observation or surveillance of such

activities.

10.4 LER 87-23 Attention to Detail

The original investigation of LER 87-23 included the separate

question as to why the RPS channe) A power supply breaker tripped

open due to an undervoltage (UV) relay shunt trip signal during.

re-energization of Division 1 DC power on June 11, 1987. Although

not the primary reason for reportability in LER-87-23, the

licensee's field engineers did pursue the cause of the spurious UV

relay operation with unsuccessful attempts to duplicate the trip.

Subsequent testing of spare relays in July 1987 resulted in

repeatable shunt trips upon re-application of DC control voltage,

and the licensee then contacted the relay manufacturer to determine

root cause.

Vendor testing in November 1987 found a subtle coupling

effect caused by wiring configurations which will be corrected with

a minor modification.

The recent test data was reported in a

revision to LER 87-23 and a Part 21 report (see Detail 5.5.1) to the

NRC on December 22, 1987.

The status of replacement of the relays

will be reported in a future supplement to LER 87-23.

The attention to detail and pursuit of root cause in this case is a

good example of the licensee's field engineering expertise and

management.

The technical understanding and level of attention to

the RPS power supplies has continued to be very high, and has

ensured good reliability for the RPS.

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111.0 Management Meetings

11.1. Preliminary Inspection Findings-

The NRC resident inspectors discussed the issues in this report

throughout the inspection period, and summarized.the findings at an

exit meeting held with the Superintendant of Operations on January

25, 1988. At the meeting, the licensee's representatives indicated

that the items discussed in this report did not involve proprietary

information.

No written inspection material was provided to

licensee representatives during the inspection period.

11.2 Regional Specialist Inspection

The inspectors attended an exit meeting for the following NRC

specialist inspection conducted at Unit 1 during the period:

Dates

-Subject

Inspection No.

Lead Inspector

January 1?-21

Emergency

.

88-01

C. Gordon

Preparedness

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