IR 05000272/1988001
| ML18093A672 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 02/11/1988 |
| From: | Swetland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18093A671 | List: |
| References | |
| 50-272-88-01, 50-272-88-1, 50-311-88-01, 50-311-88-1, NUDOCS 8802290030 | |
| Download: ML18093A672 (11) | |
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Report No Docket No License No Licensee:
Facility:
Location:
Dates:
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-272/88-01 50-311/88-01 50-272/50-311 DPR 70/DPR 75 Public Service Electric and Gas P. 0. Box 236 Hancocks Bridge, New Jersey 08038 Salem, Units 1 and 2 Hancocks Bridge, New Jersey January 4, 1988 through January 8, 1988 Inspectors:
W.A. Cook, Senior Resident Inspector, Nine Mile Point S.M. Pindale, Resident Inspector, Beaver Valley R.J. Summers, Project Engineer Approved by:
- ./d_yy Date INSPECTION SUMMARY Areas Inspected:
Announced special team inspection of the licensee's readiness for restart of Unit 1 following the 1987-1988 refueling outage including: modifications, modifications training, heat-up testing, procedures, drawings, valve lineups, Technical Specification amendments, housekeeping, ISI, Quality Assurance/Quality Control, outage management, and radiological controls practice The inspection involved 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> by the inspectors, which includes 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of backshift inspectio Results: No violations or unresolved items were identifie Licensee readiness for Unit 1 restart was considered satisfactor Minor discrepancies in the modification controls are discussed in section Inappropriate handling of incorrect Technical Specification changes is discussed in section Licen-see difficulty in understanding ECCS check valve testing acceptance criteria is discussed in section 2.3.
030 980218 8802290 05000272 PDR ADOC~
PDR G
DETAILS 1. 0 Purpose A special team inspection was conducted to evaluate the licensee's readiness to restart Unit 1 following the 1987-1988 refueling outag The team members focused on modification activities to ensure that the unit modifications were properly executed and that appropriate operator training, procedure and drawing revisions, Technical Specification amendments, and modification testing were performe The inspectors also witnessed heat-up surveillance testing, housekeeping and radiological control practice.0 Findings Modifications The following Design Change Requests (DCRs) were reviewed by the inspectors:
OCR #lEC-2186, OCR #lEC-2230, OCR #lSM-0323, OCR #lSM-0350, OCR #lEC-2065, OCR #lEC-2066, OCR #lEC-2173, Circuitry)".
Reduce Boron Concentration".
Eliminate RTD Bypass Piping".
Install Pressure Gauge to #12 RHR Pump".
Install Drain Valve at 11CS48 11 *
Pulsation Damper #13 Positive Displacement Pump 11 *
Add Charging Pump Suet ion Stabil i zer 11 *
"Install AMSAC (ATWS Mitigation System Actuation During system walkdowns, the inspectors identified no major hardware deficiencies for the modifications reviewe The inspectors did note that the drain valve installed downstream of spray valve 11CS48 (OCR #lSM-0350) and the three new valves associated with the Boron Injection Tank (BIT) sample flask (OCR
- lEC-2186) were missing identification tag The responsible maintenance management personnel were informed of these obser-vations and they indicated the missing identification tags would be promptly installe The inspectors determined that post-modification testing for the DCRs reviewed was adequat Appropriate testing methods were identified and performed and acceptance criteria was clearly state The inspector noted during review of the OCR #lSM-0323 that the inservice leakage examination was missed while the system was pressurize However, the responsible maintenance engineer was aware of this oversight and had identified the need to schedule the examination at the next possible opportunit ~... *.... *.-- -
3 The inspectors reviewed the licensed operator training material for the modifications installe The inspectors verified via discussions with licensed operators that they were cognizant of, and adequately trained on the modifications and plant operations impac The inspectors reviewed procedures and drawings to verify that they were properly updated prior to unit restar The inspec-tors identified that several control room P&IDs had not been updated as specified by the station drawing control procedur Controlled drawings are normally updated as soon as a modifi-cation is considered "construction complete".
The inspectors determined that due to a training oversight of new personnel working in the Technical Document Room (TOR), the controlled copy drawings for the control room had not been updated in a timely manne The licensee took prompt action to correct the unrevised drawings prior to the conclusion of the inspection*
and TOR personnel were properly traine The inspectors do not consider this to be a significant deficiency or a programmatic weaknes The inspectors also reviewed the computer generated plant system alignment printout to verify that the newly installed valves were incorporated into the Tagging Request Information System (TRIS). With minor exceptions, the inspectors verified that all proce-dures were properly revised prior to unit start-u While reviewing Control Console Alarm Response Procedures (ARPs) for the RTD Bypass Piping modification, the inspectors attempted to verify the procedural revisions against Unit 2 ARP However, the inspector identified that the appropriate Unit 2 ARPs for console bezels Nos. 228485, 228487, 222489 and 228507 were missing from the control roo The inspector determined that although the ARPs were missing from the Unit 2 Control Room, the master copy of the procedures was properly maintained and readily availble in the Control Room are The licensee conducted a 100% audit of the control room procedures to assure that any similar deficiencies were identified and correcte The Unit 1 ARPs that were required to be changed (as identified by the Licensee) due to the RTD bypass piping modification had been appropriately revised and the control room procedures were maintained curren However, the inspector identified that the control console ARP for bezel 202065, that governs the operators response to a delta T Deviation alarm or a TAVG Deviation alarm, states an inappropriate action for the operator, referring to the bypass loop low flow alar This action should be deleted, since the RTD bypass piping modification deleted the referenced 11 low flow" alarm.
- In*addition, during the review of procedures effected by the Boron Injection Tank, the inspector found that three procedures that should have been deleted remained on file in the control roo The licensee subsequently determined that the procedures were deleted in the procedure master file, however, the appro-priate procedure revision cover sheets had not been sent to the control room, which would have removed them from the fil The remaining required procedure revisions that were reviewed were found to be adequate and the appropriate controlled copies in plac The inspectors determined that the licensee does not conduct a periodic audit/verification that all required procedures are in the control room and are up-to-date revision The licensee committed to perform periodic verification of controlled copy procedures in the control room to prevent recurrenc During the review of OCR packages, the inspectors noted general inconsistencies in the package contents and organizatio These inconsistencies were not only betwe~n the contractor versus station generated OCR packages, but inconsistencies within the maintenance department generated packages reviewe Further, the inspectors noted that there were no master checklists (although not required) that accompanied the OCR packages which would concisely identify the status of each aspect of the modification (ie. work complete; testing complete, proce-dures revised, drawings revised, operator training complete, identification tags installed, ISI/IST program updated, etc.).
The inspectors also noted that some of the Work Orders associ-ated with each OCR broke down the modification into finite activities. Whereas other similar OCR Work Orders were less definitive (ie. fewer discreet activities identified in the Work Order).
Although the OCR package inconsistencies and the minor discrepancies noted above did not result in any significant deficiencies, the inspectors determined that a more structured or formal OCR checklist may be warranted to guard against administrative problems such as those discussed in paragraph abov The inspectors discussed this observation with licensee management and they acknowledged that they were aware of these types of inconsistencies and were working towards more uniform modification packages for improved tracking and auditin In summary, licensee modification activities appear to be well-execute Minor discrepancies were noted, but appear to be 11 growing pains 11 associated with the development of the new Planning and Scheduling Departmen The licensee was aware of many of the minor problems and inconsistencies identified and was actively addressing improvements in their modification control progra No violations were identifie. *.*'....,,. -
2.2 Technical Specification Amendment Review By letter dated October 25, 1985, as supplemented by letters dated July 31, 1986 and October 24, 1986, the licensee requested changes to both Unit 1 and Unit 2 Technical Specifications (TSs).
The request was to delete the TSs relating to boron concentration in the boron injection tank (BIT) and the associated heat tracing required to maintain the high boron concentration in solutio On April 7, 1987, NRC Licensing issued Amendment Nos. 78 and 52 for Units 1 and 2, respectivel The amendments deleted the TSs affected by the above reques The amendment became effective upon its date of issuanc The licensee recognized that the TS amendments could not be implemented until a refueling outage was completed for each unit, and the actual hardware modifications were complete Therefore, the licensee issued an internal memorandum stating that the amendments would not be formally implemented until the modifications were completed (7th refuel-ing outage for Unit 1 and 4th refueling outage for Unit 2).
This memorandum was placed in both the Unit 1 and Unit 2 TS Unit 1 and Unit 2 Operations shift personnel were instructed to continue to follow the existing TS and applicable procedures until the respective outages and associated modifications were complet The inspectors questioned the licensee's approach for not implementing a formally issued TS amendmen The licensee stated that their TS change request did document the need to delay implementation of the TS amendments until the modifica-tions were complete The licensee further stated that after the issuance of the TS amendments NRC Licensing was verbally notified of their intent to delay implementing the TS amendments and the NRC Licensing representatives determined this approach to be acceptabl The NRC team inspectors requested that the licensee submit to the NRC staff a letter documenting their action regarding the delay in implementing this TS amendmen The licensee agreed to take this actio Since the BIT modifi-cations have already been performed on Unit 1, only the Unit 2 TS amendment needs to be addressed in the letter to the NR No further discrepancies were identified associated with the above TS amendment By letter dated March 10, 1987, as supplemented by letters dated June 24, 1987 and July 9, 1987, the licensee requested changes to both Unit 1 and Unit 2 TS This request was to change the TSs regarding boron concentration in the refueling water storage tanks (RWSTs) and accumulator The March 10, 1987 submittal requested in part, that the required Unit 1 RWST volume for Modes 1 through 4 be changed from between 364,000 and 400,000 to between 364,500 and 400,000 gallon However, the supplemental
request dated June 24, 1987, which was submitted to correct TS page numbering on both units, inadvertently changed the RWST volume range for both units to 364,000 - 400,000 gallon Con-sequently, the TS amendments (Nos. 83 and 55 for Unit 1 and Unit 2, respectively), were issued on Oct. 16, 1987, using the wrong RWST volume range for both unit During a review of the TS change request and amendment issuance, the inspector noted two 11 pen-and-ink 11 changes to Unit 1 TS 3.5.5, Refueling Water Storage Tan The first was a change to the existing RWST volume range from "between 364,000 and 400,000 gallons 11 to "between 364,500 and 400,000 gallons 11 *
The second was a change to the RWST boron concentration range from 11 between 2,000 and 2,000 ppm 11 to 11between 2,000 and 2,200 ppm 11 *
Addi-tionally, a 11 pen-and-ink 11 change was found on Unit 1 TS 3.1.2.8, Borating Water Sources, correcting the same RWST volume range number The effective date of this TS amendment was December 27, 1982 (Amendment No. 50).
The licensee stated that these 11 pen-and-ink.
11 changes were made with concurrence from NRC Licensing and were made to correct administrative errors during the change request and amendment issuance proces Similar 11pen-and-ink 11 type changes were found on the Unit 2 TS With regard to the RWST TS amendments (Nos. 83 and 55), which were issued in error for both units, the licensee agreed that 11 pen-and-ink 11 changes would not be appropriate for future use and that a formal TS change request would be initiated to cor-rect these administrative error TS amendment Nos. 83 and 55 did correct the RWST volume ranges.for the Borated Water Sources TS sections for both Units 1 and The licensee stated that plant operators will be instructed on what the correct RWST volume range numbers ar Issuance of the revised TS amendments will be reviewed through the routine resident inspection progra By letter dated May 5, 1987, as supplemented by letters dated September 2, September 17 and October 1, 1987, the licensee requested changes to both Unit 1 and Unit 2 TS This request was ostensibly for the purpose of changing the Reactor Protection System and Emergency Safety Features response times to accommodate the removal of the RTD bypass pipin Additional changes to the TSs were included with this request to achieve consistency between the unit These changes involved:
adding a requirement for Auxiliary Feedwater Response Time to Unit 1, to be consistent with Unit 2; adding a Station Blackout (item 14) requirement to Unit 2, to be consistent with Unit l; correcting typographical errors in the Unit 1 TSs, to be consistent with Unit ** * *
Consequently, the TS Amendments (Nos. 84 and 56 for Unit 1 and Unit 2 respectively), were issued on November 16, 198 The amendments were both effective upon date of issuanc The effective date for Unit 2 was in error since the required modifications to the plant had not yet been complete The licensee operations department had recognized this problem and therefore had not yet issued the TS change to the Unit 2 control room nor had they initiated changes to plant procedures based on the new TSs as ye The inspector agreed that the issuance of the Unit 2 TS change had occurred prematurel The inspector requested that the licensee formally notify the NRC that the inappropriate changes to the Unit 2 TSs would not be implemented until such time that the hardware changes are incorporated into the plan Conclusions The inspectors determined that the above identified problems, namely the informal mechanism to change or correct the facility TSs and/or the decision to not implement TSs, is a significant weakness in maintaining the license current and accurat This informal method in maintaining the quality of the license is not consistent with the administrative controls established for maintaining "lower tier" documents such as station or department procedure Region I notified NRR of the license amendment discrepancie This matter is considered unresolved pending licensee formal request and NRR issuance of the appropriate license chang (272/88-01-01; 311/88-01-01)
Review of Check Valve Testing The inspector observed the conduct of leak rate testing on the reactor coolant system pressure isolation valve This testing is required by Technical Specification surveillance requirement 4.4.6.3, in which the listed valves are to be demonstrated operable each time the plant is shutdown for refuelin While observing this test, the inspector observed that the stated acceptance criteria in both the technical specification and the licensee 1 s test procedure (SP(o)4.4.6.3 Emergency Core Cooling System - ECCS Subsystems, Rev. 6, dated 7/13/87) are being improperly interprete One of the acceptance criteria is based on the margin between the measured leakage rate and the maximum permissible rate of 5.0 gpm at an assumed normal operating pressure (2235 psig). Because the licensee conducts the test at a pressure lower than normal operating pressure, the measured leakage rate must be adjusted (multiplied by a correction factor) to determine the calculated leakage rate at 2235 psi The operators and system engineer were comparing the measured leakage rates at the test pressure to the maximum rate of 5.0 gpm.
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- Since the maximum value of 5.0 gpm is a rate determined at 2235 psig, then the comparison of leak rates should also be based at a common pressure parameter. Therefore the acceptance criteria should have been applied to the "calculated leakage rate 11, the measured leakage rate corrected to an equivalent value at 2235 psi The inspector immediately identified this fact to the licensee, at which time the licensee conducted a review of the test acceptance criteri Upon further evaluation the licensee determined that based on the appropriate interpretation of the acceptance criteria, that a number of the pressure isolation valve(s) leak rates were considered unacceptabl The licensee then conducted a review of the test procedure lineup and determined that the test results were being biased as a result of inleakage from the Refueling Water Storage Tank to the test lineu When the licensee isolated this inleakage flow path, the test results were demonstrated as satisfactory. It was also determined that the licensee had previously interpreted the acceptance criteria properly and that this problem appeared to be an isolated cas Although the inspector had no concern with the equipment operability, there was a concern that the inspector had to become involved in order that the acceptance criteria were properly applie This concern was discussed with licensee. management at the exit meeting, at which time the licensee committed to review similar procedures (Unit 2) to assure that the acceptance criteria are being properly interprete Housekeeping and Radiological Controls During tours of the facility and system walkdowns, the inspectors observed housekeeping and radiological controls practice No significant weaknesses were note Areas inside the Auxiliary Building and Containment which were dirty or cluttered with outage related equipment, tools or materials were either being cleaned or scheduled to be cleaned prior to unit startu Licensee general radiological control practices and station personnel sensitivity to the spread of contamination were observed to be goo No violations were identifie.5 Inservice Inspection Activities Review The inspector reviewed a pre-outage checklist of planned !SI activitie Review of ISI documentation and discussions with licen-see personnel indicated that the checklist was essentially completed during the outag ISI outage activity documentation reviewed by the inspector included containment integrated leak rate testing, several Type C local leak rate tests, feedwater ring J-tube examinations, system hydrostatic testing and secondary plant piping thickness
- monitorin A sample of documented test failures and other defi-ciencies identified during testing were reviewed by the inspector and found to have been adequately resolved by the license No concerns were identified in this are.6 Quality Assurance/Quality Control Review The inspector interviewed QA/QC personnel and reviewed QA surveil-lance and audit records to determine the extent of QA/QC coverage of outage related activitie The inspector found the coverage to be comprehensive in that a wide variety of activities were monitore The activities covered were documented on separate QA surveillance sheet The content and conclusions documented on the surveillance sheets reviewed by the inspector reflect that outage-related work and work activities were generally adequat A number of findings were documented during QA/QC coverage of the outage-related activitie The findings were documented, forwarded to the responsible sections and tracked by the QA organization for resolutio The inspector confirmed that the findings received proper attention by the various responsible station group The inspector determined that no addi-tional NRC followup was warrante The QA organization also performed an in-the-field audit of plant activitie The inspector reviewed the associated audit report (N NM-87-26).
The audit concluded that the selected portions of the Quality Assurance Program have been effectively implemented by plant personne A number of minor program deficiencies and concerns were identifie The inspector confirmed that deficiency reports were initiated and issued to the appropriate organization on sit The status of the resolution of these findings was being tracked by the QA organizatio No discrepancies were note.7 Management Outage Oversight The inspector discussed outage activity coordination and oversight with the licensee and determined that this was the first refueling outage planned and executed by the new Planning and Scheduling Departmen As discussed earlier in this inspection report, the licensee has experienced minor difficulties with the tracking of certain modification activities, but was cognizant of those problem area The primary tracking system used by the licensee during outages is the Management Maintenance Information System (MMIS) and it appears to be effectively utilized and understood by the licensee.
The inspectors also attended daily status and planning meetings held by station management and observed licensed operator turnovers and briefing The inspectors observed that these meetings and briefing were well structured, thorough and concise, and that meaningful exchanges of unit status, identified problems and scheduled evolu-tions were taking plac.0 Conclusions Based upon their review of completed outage activities and heat-up activities observed, the inspection team concluded that the licensee was adequately prepared to restart Unit 1 followup of the 1987-1988 refueling outag The discrepancies noted do not indicate any programmatic weakness or deficiencie In general, the refueling startup was well planned and execute.0 Exit Meetings At periodic intervals and at the conclusion of the inspection, meetings were held with senior station management to discuss the scope and findings of this inspectio Based on the NRC Region I review of this report and discussions held with licensee representatives, it was determined that this report does not contain Safeguards or 10 CFR 2.790 information.
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ATTACHMENT A Licensee Commitments Made During NRC Inspection No. 50-272/88-01 and 50-311/88-01 Commitment Report Section Perform periodic verification of controlled copy procedures in the control roo Submit documentation to the NRC:NRR regarding delay of implementing a T.S. regarding the Boron Injection Tan Instruct operators on correct RWST volume requirements and submit a T.S. change to correct typographical errors, Submit documentation to the NRC:NRR regarding delay of implementing a T.S. change due to modification of loop RTD bypass pipin Review procedures to assure valve leak rate acceptance criteria is properly interprete *.. * "\\
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