IR 05000272/1997010
| ML18102B479 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 07/31/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18102B478 | List: |
| References | |
| 50-272-97-10, 50-311-97-10, NUDOCS 9708080019 | |
| Download: ML18102B479 (19) | |
Text
Docket Nos:
License Nos:
Report N Licensee: *
Facility:
Location:
Dates:
Inspectors:
Approved by:
U. S. NUCLEAR REGULATORY COMMISSION 50-272, 50-311 DPR-70, DPR-75
REGION I
50-272/97-10, 50-311/97-10 Public Service Electric and Gas Company Salem Nuclear Gerierating Station, Units 1 & 2 Hancocks Bridge, New Jersey April 14 - June 14, 1997 R.L. Fuhrmeister, Sr. Reactor Engineer A.G. Quirk, NRC Contract Engineer C. Marschall, Sr. Resident Inspector William H. Ruland, Chief
- Electrical Engineering Branch
. Division of Reactor Safety 9708080019 970731 PDR ADOCK 05000272 G
EXECUTIVE SUMMARY Salem Nuclear Generating Station NRC Inspection Report 50-272/97-10, 50-311/97-10 This combined inspection covered aspects of the testing for the startup of Salem Unit Engineering The NRC has closed the remaining two restart items, P22 - Restart Test Program -
and T45 - Containment Fan Cooling Unit (CFCU) modification Two non-cited violations were identified relating to the content of Control Room Ventilation test procedures and deficiencies in the conduct of testing. These deficiencies were also identified by PSE&G's Test Review Boar Service Water System integrated testing to demonstrate modifications made to mitigate water hammer in the safety related portions of the system was well-implemente The Test Review Board was found to be effective in identifying testing deficiencies and initiating corrective action A non-cited violation was identified relating to improper conduct of diesel generator post-modification testin In response to inspector questions, engineering staff clarified the design basis documentation of the seasonal nature of freeze protection for the containment fan coil unit (CFCU) modification. The inspectors considered the lack of clear documentation to support operability of the CFCUs a weakness.
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TABLE OF CONTENTS PAGE EXECUTIVE SUMMARY............................................. ii Ill. Engineering...................................................
E1 Conduct of Engineering........................................
E1.1 Control Room Ventilation Testing (37S2S)......................
E1.2 Service Water Testing Required for Startup (70304)............... 4 E1.3 NRC Restart Item 11.45 - Containment Fan Coil Unit (CFCU)
Modification, Startup Issue T24.............................
E3 Engineering Procedures and Documentation..........................
E Post-Modification Test Program Revision (72400).................
E4 Engineering Staff Knowledge and Performance........................
S E Diesel Generator Air Start System Testing (72301)................
S E7 Quality Assurance in Engineering Activities...........................
E7.1 Test Review Board Activities (70400).........................
ES Miscellaneous Engineering Activities..............................
ES. 1 (Discussed) Violation 50-311196-21-01, Control Room Ventilation Test Procedure Inadequacies..............................
1 E (Closed) Violation 50-311197-06-01, Testing Not Performed in Accordance with Approved Procedures.......................
E (Closed) Restart Issue P22, Integrated Test Program, Unit 2........
13 Management Meetings........................................
X 1 Exit Meeting Summary........................................
PARTIAL LIST OF PERSONS CONTACTED...............................
1 5 LIST OF INSPECTION PROCEDURES USED
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LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED.......................
LIST OF ACRONYMS. USED.........................................
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- E1 E1.1 ~---
Report Details Summary of Plant Status Ill. Engineering Conduct of Engineering Control Room Ventilation Testing (37828)
Scope of Inspection Design Change Package (DCP) series 1 EC-3505 made extensive modifications to the control area ventilation (CAV) system. The inspector reviewed the completed test procedures listed below to evaluate the post-modification testing which had been performed:
1 EC-3505 Package No. 1 (-1 ), Special Test Procedure (STP) - 3, Control Area Ventilation (CAV) Testing and Balancing 1 EC-3505-1, STP-5,.Control Room Emergency Ventilation (CREV) System Filter Acceptance Test (Unit 2)
1 EC-3505-1, STP-6, CREV System Filter Acceptance Test (Unit 1)
1 EC-3505-2, post modification testing (Work Book Section 10) and STP-1, Control Room Ventilation Emergency Air Conditioning System (EACS) Drain Sight Glass and Loop Seal Test 1 EC-3505-3, Work Book Section 10 and STP-1, Units 1 and 2 Control R1 B Radiation Monitors 1 EC-3505-5, STP:.1, Flow Testing on Unit 2 Chilled Water System 1 EC-3505-7, STP-1, Flow Testing on Unit 1 Chilled Water System_
1 EC-3505-7, STP-2, Flow Balancing Chilled Water Emergency Control Air Compressor Network Onl EC-3505-11, STP-1, CAV Final Testing/Balancing 1 EC-3505-11, STP-2, Quantify Recorder Panel (RP) Air Flow Leakage/Control Room Envelope Pressurization for Leak Detection
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2 Observations and Findings The tests reviewed included additional examples of problems identified in the Notices of Violation (NOVs) issued with NRC Inspection Report (IR) 50-311 /96-21 (test procedures not consistent with plant procedures) and Combined Inspection Report 50-272/97-06 and 50-311197-06 (failure to follow test procedures). Most of these deficiencies were encountered in 1 EC-3505, Package No.1, STP-3, which balanced the ventilation air flow in the in the control buildin Test procedure 1 EC-3505-1, STP-3, had initial conditions which were not well defined. NC.DE-AP.ZZ-0012(0), Test Program, Form NC.DE-AP.ZZ-0012-4, Special Test Procedure Cover Sheet, Format and Guidelines requires a section which establishes initial conditions. The 1 EC-3505-1 ~ STP-3 test procedure did not adequately address support system status, and did not have blocks for signing off the establishment of Initial Conditions. These are additional examples of problems previously identified in the Notices of Violation issued with NRC IR 50-311196-21.
This matter is not being cited for enforcement action in accordance with Section Vll.B.1 of the "General Statement of Policy and Procedures for NRC Enforcement Actions (Enforcement Policy) NUREG-1600, since this was also identified by the Test Review Board, (the testing was completed prior to April 1997), and corrective actions were initiated. (NCV 50-311/97-10-01)
Public Service Electric and Gas Company (PSE&G) experienced significant pro.blems executing 1 EC-3505-1, STP-3, apparently because of leaks from the control room to the surrounding areas. These problems resulted in sections of the test being re-performed several times as various problems were resolved and dampers adjuste The Modifications/Concerns Resolution (MCR) *process also resulted in multiple copies of individual test procedure pages. An additional complicating factor was that the testing was performed by two different contractors at different time The issues noted in the previous paragraph were compounded by minimal use of the test remarks section. Form NC.DE-AP.ZZ-0012-4, Special Test Procedure_ Cover Sheet, Format and Guidelines requires a remarks section which " **. is used to list any problems encountered during the testing along with any notes and comments on the performance of the test." The minimal use of the test remarks* section, combined with test complexities noted in the previous paragraph, made it difficult for the NRC inspector and the PSE&G Test Review Board (TRB) to review the test results. Both the NRC inspector and TRB identified a number of problems with the completed test. As was the case for all but two of the STPs reviewed this inspection period, no record of required post-test calibration of test equipment was included in the test package. As a result of problems associated with the test conduct, the TRB did not approve the test results, and required testing was reperformed under special test procedure 1 EC-3505-11, STP- *
1 EC-3505-11, STP-1 re-balanced the CAV airflows after additional changes were made to the ventilation system. The test results were much easier to follow than the earlier test package described above. There were a few minor deficiencies noted by the Test Review Boar CREV filter acceptance tests, 1 EC-3505-1, STP-5 and STP-6, had some problems both in test format and results. Contrary to requirements on Form NC.DE-AP.ZZ-0012-4, the tests did not include sections for scope, background, initial conditions, references, or remarks. As in 1 EC-3505-1, STP-3, no spaces were provided for a signature verifying initial conditions were met. No special test equipment was listed, but some special test equipment was used, including a precision air velocity meter. The actual test results were easier to understand than those in 1 EC-3505-1 STP-3, and the use of the test remarks section was better. However, there were still some test documentation inadequacies. For example, during 1 EC-3505-:1, STP-5 testing on February 4, 1 997, makeup flow exceeded the limit of 1000 CFM in step 5. 7.15, but there was no record of this on Form-9, "Troubleshooting."
However, when the test was reconducted on March 3, 1997, the flow limit was not exceeded, but there was no explanation for why the test passed the second tim These are additional examples of the violations cited in NRG IRs 50-311196-21 and 50-311/97-06. These are not being cited, in accordance with Section Vll.B.1 of the Enforcement Policy, since the general issues were identified by PSE&G as part of an ongoing corrective action for the prior similar violations, corrective actions were in progress at the time the inspection ended and had not yet been fully implemented, and the testing was subsequently reperformed satisfactorily. (NCV 50-311/
97-10-02)
DCP 1 EC-3505-2 post-modification testing and STP-1 were limited due to th limited scope of this package. The STP called for adding water to the loop seal to *
establish the initial level in the sight glass. The STP functional test then ensured the new loop_ seal was working by marking the level on the loop seal sight glass with the CREV fans off, starting the fans, ~topping the fans, and ensuring the level was within 0.5 inches of the original level. A full functional test would have observed the level to increase when the fans were started and then decrease to the original level when ttie fans were stopped. However, this was not required by the test procedure. Additionally, the only acceptance criterion in the STP was "All steps have been satisfactorily completed. Record remarks on Attachment 7. 1 ".
The TRB concluded this criterion was weak, and should have been corrected prior to conducting the tes The TRB Chairman stated the TRB did not review all of the CAV tests during the System Readiness Review. He indicated this was an isolated case due to delays in preparing the various tests, as well as the gradual increase in scope of the associated modifications. PSE&G realized this was one of the contributing factors to the problems in the Inspection Report 50-311/96-21 violation, and has modified site procedures to ensure test procedures are reviewed prior to future final System Readiness Reviews.
DCP 1 EC-3505-3, Section 10 and STP-1 test *procedures were found to be adequate. The first steps in the section 10 test verified generic vendor information for the new radiation monitors and digital recorders which was used to develop the STP was consistent with specific information provided with the delivered equipment. The STP was properly prepared in the format specified by NC.DE-AP.ZZ-0012(0) Test Program. The test remarks section was appropriately used, and exceptions and punch list items were clearly marke Testing completed for 1 EC-3505-5, STP-1 and 1 EC-3505-7, STP-1 and STP-2 *were also among the better packages reviewed. Use of the test remarks section could be improved, and test acceptance criteria could have been made more explicit. One acceptance criterion _was to provide data to Engineering for review; the test required a signature that the data was reviewed and acceptable. However, the basis for the acceptability was not clearly defined. It was possible to follow most of the testin Conclusions The inspector identified additional examples of problems cited in two recent NRC violations. These problems are less significant and fewer in nurriber than those which led to the original violations. Test 1 EC-3505-1, STP-3 was completed prior to issuing violation 50-311/97-06-01 and had the most problems. The test results were reviewed and approved by the Level II and Level Ill test engineers but were not accepted by the TRB. The fact that TRB rejected the test results was appropriate, but the failure of the Level II and Ill to properly review the results is an example of problems identified in the earlier violations. The re-testing completed under 1 EC-3505-11 STP-1 and STP-2 was adequat These failures to comply with requirements are not being cited for enforcement action, in accordance with Section Vll.8.1 of the Enforcement Policy (NUREG-1600), since.most of them were identified by PSE&G as part of an ongoing corrective action for a prior similar violatioi:1, corrective actions were in progress at the end of the inspection, and the testing was subsequently reperformed satisfactoril E1.2 Service Water Testing Required for Startup 170304) Scope of Inspection The inspector reviewed DCP testing and test procedures for modifications to the service water (SW) system being performed to mitigate the effects of water hammer which could result from certain loss of AC power transient Specific documents reviewed included:
2EC-3590-3, Service Water Column Separation Protection No. 21 & 22 2EC-3590-4, Service Water Column Separation Protection No. 21 Nuclear Header 2EC-3590-16, 96-06 Modifications, Integrated Testing, Rev. 0
- TS2.SE-SU.SW-0003(0), SW System Modification Validation Test, Rev 2, 3, and 4. Observations and Findings Prior to issuance of NRC Generic Letter (GL) 96-06, PSE&G had performed an evaluation of the SW system and the piping which supplies the containment fan cooler units (CFCU). That evaluation determined that the SW system would be subject to column separation water hammer during certain loss of AC power transients. The evaluation concluded that the pressure boundary integrity of the SW piping would not be challenged by the resulting pressure transient. The evaluation noted that on several occasions, the Salem Generating Station (SGS) had in fact experienced water hammer during loss of AC power event In response to GL 96-06, PSE&G evaluated the effects of the potential "worst-case" transient on the piping supports and the CFCU tubes. PSE&G determined that the CFCU tubes needed protection from the postulated pressure transien The mitigation method selected involves the installation of two large accumulators tied to the SW supply headers through fast-acting valves. The sizing of the accumulators and the stroke times for the valves were selected based on the SW system computer model results for the conditions representing the transient. Each accumulator discharge line has two fast-acting valves, connected in parallel, located in the SW valve rooms in the auxiliary building. The valves receive their open signal from new undervoltage relays sensing the voltage on the safety-related 4kV busse The specified testing included calibration of the level and pressure transmitters for the accumulators, pressure tests of the newly installed piping, stroke adjustments of
- the air-operated fast-acting valves, limit switch setting for valve position indicators, and transient testing wherein the 22 SW header was subjected to the transient which is anti!'::ipated to occur under worst-case loss of AC power scenario. The dynamic testing measured pressures and f~ows at various places throughout the system to ensure that neither excessive pressure nor flow instabilities occurre The dynamic testing included simulation of the limiting hot weather and cold weather system configuration The inspect9r compared the test sequences in TS2.SE-SU.SW-0003(Q) with those described in DCP 2EC-3590-16, and found them to match. Th.e initial conditions and equipment specified to be operating were also found to match. During actual conduct of the test, the 26 SW strainer failed due to unrelated problems (debris ingestion) and substitutions for the 26 SW pump and strainer were incorporated into the test procedure. In addition, during the first transient test sequence, joint leakage occurred at bolted connections in the nonsafety-related turbine building portions of the system. Steps were added to subsequent test sequences to maintain an air cushion in the nonsafety-related portions of the system to prevent recurrence.
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6 Conclusions The inspector considered the SW testing to be well-planned and controlled, based
- on the integrated test procedure including all the testing specified in the DCP, and the test procedure being revised to compensate for equipment problems which arose during the conduct of the testin E1.3 NRC Restart Item 11.45 - Containment Fan Coil Unit (CFCU) Modification Inspection Scope The inspectors reviewed licensee controls to ensure that the modification implemented appropriate measures to ensure freeze protection and tamper preventio Observations and Findings During review of the installation of the service water surge tanks installed as part of the CFCU modification, inspectors noted that the design documents required installation of an enclosure around the tanks and heaters with the enclosure. The licensee intended the heaters to ensure that the water in the surge tanks and associi;lted piping would not freeze. The inspectors noted that, although the licensee intended to complete installation of the enclosure and heaters prior to cold weather, the licensee did not plan to complete the installation of these components prior to entering mode 4. The inspectors questioned the basis for the licensee's intent to enter mode 4 prior to completing the installation, since the licensing basis required operability of the modification to ensure containment integrity in modes 1 through 4. In response, the engineering staff changed the design description to specify that the enclosure and heaters were seasonal requirements, and that they would comptete installation prior to the onset of cold weathe Due to the location of the surge*tanks, the inspectors also questioned the lack of measures to prevent tampering with the surge tanks. As a result, the lic~nsee implemented effective measures to ensure that the tanks remained capable of discharging the required volume of water into the service water system, as required by the desig Conclusions The inspectors concluded that containment fan coil unit modification design documents did not clearly capture the intended seasonal nature of freeze protection features for the associated service water surge tanks. The licensee promptly clarified the design documents. Considering the location of the tanks, the engineering staff also implemented reasonable and effective measures to prevent tampering. The inspectors concluded that, although not completing the freeze
protection measures did not adversely impact operability of containment or the CFCUs, the lack of a clearly documented tie between the freeze protection and the seasonal nature of its effect on operability indicated a continued need to improve the engineering understanding of the basis for equipment operabilit The inspectors concluded the implementation of the CFCU modification restart issue T45 was adequate to support Unit 2 restar E3 Engineering Procedures and Documentation E Post-Modification Test Program Revision (72400) Scope of Inspection The 'inspector reviewed the new governing procedure for the Post-Modification Test Program, SH.Pl-AP.ZZ-0012(0), Rev. 0, Modification Test Program, dated May 2, 1997. The effective date of the procedure was May 9, 199 Observations and Findings During previous inspections of the Integrated Test Program for the startup of Salem Generating Station Unit 2, the inspectors identified deficiencies in STPs generated as part of the DCPs. Those procedures were generated in accordance with a Design Engineering procedure, NC.DE-AP.ZZ-0012(0), and used a procedure format
. and content unique within the Nuclear Business Unit (NBU). In an attempt to improve procedure quality and consistency, the governing document was revised to a Salem and Hope Creek common document, and the format and content were standardized with other procedures within the NBU. The organization responsible for maintaining and updating the procedure is Project Management and Installation, within the Maintenance Departmen The new procedure provides guidance for specifying and conducting modification testing. The guidance applies to post-modification testing of structures, ~ystems, and components which have been newly installed, restored, or modified under the change package process, as well as for infrequently performed tests or evolutions performed qS part of the change package process. The test conduct requirements are intended to improve plant safety margin,* and promote open communication between test personnel, supervisors, and senior managemen The procedure calls for developing test instructions in accordance with the station Procedure Writers Guide, NC.NA-WG.ZZ-0001 (Q). In addition, the requirements of NC.NA-AP.ZZ-0001 (Q), Nuclear Procedure System, for procedure control and use, are invoked by reference. The procedure also requires the use of a Chronological Test Log, which is to be used to record test activities and problems in sufficient detail that an accurate reconstruction of testing activities can be performe *
c.
Conclusions The inspector concluded that, if properly implemented, the new procedure should resolve the problems with post-modification testing which have been identified by both NRC and PSE&G. This conclusion is based on a review of the previously identified post-modification test procedure and test conduct problems, and the enhancements to post-modification testing being implemented in the new Modification Test Program procedur E4 Engineering Staff Knowledge and Performance E Diesel Generator Air Start System Testing (72301 l Scope of Inspection The inspector reviewed Action Request (AR) 970606323, which described deficiencies relating to emergency diesel generator (EOG) air start system testing, and DCP 2EC-3349, Package 3, "2C EDG Starting Air & Turbo Boost System Upgrade." The inspector also discussed the circumstances surrounding the event with the newly appointed test group superviso Observations and Findings During this inspection period, testing personnel identified that post-modification testing for the EDG air start systems may have been inadequate. The testing called for performing three starts of the engine from each receiver and its associated starting motor to verify that the modified air start system had sufficient capacity to meet the design basis. However, no criteria were included in the test procedure to define a "cold start." The test procedure referred the test engineer to a surveillance test procedu[e for performing the actual start of the engine. The surveillance procedure also called for running the engi11e for a minimum time to avoid deleterious effects on the engine (e.g. carbon buildup in the cylinders, moisture accumulation in.
the lubricating oil). The minimum run time resulted in the engine oil temp_erature rising above 150 degrees Fahrenheit (°F) before the engine was shut down. Test group personnel determined that the cold start conditions required a lubricating oil temperatur~ in the range of 100-140° The cold start oil temperature criteria were added to the test procedure for the 1 B EDG. During the performance of the testing on the 1 B EDG, the test engineer identified that the oil temperature was approximately 155°F at the end of the first run. The reason for the limit on oil temperature at start was not imm.ediately apparent, and the test engineer discussed the matter with the system manager for the EDGs. The system manager determined that the higher temperature at start would not adversely impact the engine, and testing was continued with the subsequent starts at the higher oil temperatur *
Test engineer review of the completed test data identified that the subsequent starts were conducted outside the specified range of oil temperatures. Corrective actions were initiated, including upgrading training for test engineers, and performing confirmatory testing in the form of "cold starts" on the 1 B EO Comparing the "cold start" data for the 1 B EOG with that obtained during the previous testing (without the "cold start" criteria) revealed that there was not a significant change in the performance. of the starting air system at the different engine temperature The apparent failure to perform testing in conformance with the approved procedure is considered to be a non-cited violation in accordance with Section Vll.B.1 of the Enforcement Policy, since it was identified by PSE&G, corrective actions were initiated, and retesting of the 1 B EOG at "cold" conditions provided assurance that the test data obtained at the higher temperatures are sufficient to confirm the modified air start system meets its design. (NCV 50-272/97-10-03) Conclusions Based on the identification of the testing deficiencies by PSE&G, and the initiation of corrective actions, including the retesting of the 1 B EOG, the inspector.concluded that PSE&G test program management can effectively identify and resolve testing deficiencie E7 Quality Assurance in Engineering Activities E Test Review Board Activities (70400) Scope of Inspection The inspectors monitored the activities of the PSE&G Test Review Board (TRB)
during their reviews of System Test Plan revisions~ Test Procedure reviews, and completed test data review Observations and Findings In response.to the NRC finding of inadequacies in test procedure performance documented in NRC Inspection Report CIR) 50-311/97-06, PSE&G expanded the scope of reviews performed by the TRB to include completed tests and associated data. PSE&G management directed the TRB to review all completed ventilation system testing, as well as selected non-ventilation system tests, to evaluate procedure compliance during testing and whether test results met the established acceptance criteri TRB review of the control room, auxiliary building, and penetration area ventilation system testing revealed test conduct deficiencies in addition to those cited in the NOV issued with IR 50-311197-06. The TRB documented its findings in condition reports (CRs) for evaluation and correction. Corrective actions included revisions of test procedures, evaluations performed by engineering to determine the
acceptability of actual test results, reperforming testing, and retraining and requalifying test personnel. In many cases, TRB specified that the corrective actions required completion prior to making the change to Mode 4 (plant heatup above cold shutdown). In addition, critical path modification work and testing *on the Control Room Ventilation system, which had not yet been completed, was not permitted to be closed out for turnover to Operations until TRB had reviewed and approved the test result The TRB review of System Test Plan revisions included reviews of the post-modification testing to be performed to confirm proper modification implementatio During review of Revision 2 of the Control Area Ventilation System Test Plan, TRB determined that several minor modifications did not have post-modification tests written, nor were acceptance criteria for the testing developed.* Approval of the revision was withheld pending completion of development of the test procedure Conclusions Based on the observations of the TRB actions at the meetings, and verification that the TRB-generated condition reports were entered onto the mode change restraint lists, the inspector concluded that the TRB was effective in identifying deficiencies in testing, and causing timely corrective actions to be taken by the appropriate groups throughout the Salem operating organizatio ES Miscellaneous Engineering Activities E (Discussed) Violation 50-311196-21-01. Control Room Ventilation Test Procedure Inadequacies Scope of Inspection
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The inspector reviewed PSE&G corrective.actions for the Notice of Violation (NOV)
issued with NRC IR 50-311/96-21. The violation addressed inadequacies in the format and content of post-modification test procedures for CA Observations and Findings The previous inspection finding was that test procedures were not in compliance with NC.DE-AP.ZZ-0012(0), "Test Program," Section 5.1, "Test Procedure Development." Specifically, 1 EC-3505-1, STP-1, "Integrated Test of Control Area Air Conditioning System (CAACS)/Emergency Air Conditioning System (EACS)," had a number of instances of not establishing or documenting initial conditions for test sections. 1 EC-3505-1, STP-3 did not consistently use test step signoffs. In response to this finding, PSE&G reviewed these specific procedures, the remaining CAV test procedures and several non-CAV test procedures to determine the extent of the problems. PSE&G determined that no additional CAV procedures needed revision. However, two* non-CAV procedures were revised. These corrective actions were completed in late-January 1997, and are described in the PSE&G response to the.NOV dated April 11, 199 *
While PSE&G did correct the specific problems identified in IR 50-311 /96-21, the extent of condition review appears to have not been fully effective. Additional examples of procedure content problems were subsequently discovered by both NRC and the PSE&G TRB, as documented in NRC IR 50-311197-06. PSE&G has been requested to review its response to the NOV and revise it as necessary to address these additional example Conclusions Based on the additional examples of procedural content problems identified by both the NRC and PSE&G, this item will remain open, pending completion and NRC review of the PSE&G corrective action E (Closed) Violation 50-311197-06-01, Testing Not Performed in Accordance with Approved Procedures Background During the NRC inspection documented in IR 97-06, a review was conducted of completed testing on the CAV system. That review identified several instances where procedural requirements were not met during the testin The inspector reviewed PSE&G actions taken in response to the finding, including those actions documented in PSE&G letters dated June 30 and July 16, 1997, and the corrective actions documented in the following Performance Improvement Requests (PIRs):
970310189, DCP 3505 Design Deficiencies 970320247, Inappropriate Response to DCP 1 EC-3505 Testing 9703~5258, Lack of Design Engineer Signoff for Test Acceptance 970326255, Incorrect test Pressurf'.l Specified in DCP Testing 970415322, Conduct of Post-Modification Testing 970506278, 1 EC-3505, Package 1, STP-1 970507081, 1 EC-3505, Package 1, STP-5 970507085, 1 EC-3505, Package 1, STP-6 970507100, 1 EC-3505, Package 5, STP-1, Second Test 970506307, 1 EC-3505, package 1, STP-4 970507103, 1EC-3505, Package 7, STP-1 970506339, 1 EC-3505, Package 1, STP-2 Observations and Findings In response to the initial NRC finding, PSE&G management directed the TRB to review all completed CAV testing, as well as representative examples of non-ventilation testin *
The TRB review identified a number of additional examples of test procedure noncompliance and test procedure inadequacies (see Section E7. 1 ). These were documented in CRs and entered. into the PSE&G corrective action program. Where appropriate, the TRB required corrective actions to be completed prior to entry into Mode 4 (plant heatup).
NOV example 1 : Cooling coil inspection acceptance criterion was not met and an AR to clean the coil was not initiated: The chalky white film on the coil was evaluated and determined to be lead oxide. PSE&G determined the source of the film to be the result of chemical cleaning of the coil during the manufacturing process. Consultation with the manufacturer determined that this film will not reduce the heat transfer capability of the coil. The acceptance criteria for the cooling coils 1 HVE200 and 2HVE200 were revised via administrative change at the time of package final closure in June 199 NOV example 2: Filter housing leakage rates were outside the established acceptance criteria, but the test results were approved and the EACS system was returned to service: MCR 193 to design change 1 EC-3505 evaluated the measured leakage rates and found them to be acceptable, as documented in IR 97-06. This was based upon the measured leakage being less than the leakage assumed in the Control Room dose calculation. A stated in IR 97-06 details, Section E4.1, MCR 193 did not revise the acceptance criteria. The acceptance criterion for filter housing leakage were revised by administrative change at the time of final package closure in June 1997. While the revisions by administrative change and not MCR193 is different than stated in the PSE&G response dated July 16, 1997, that difference is not material since the change was still mad NOV examole 3: Test oressures were less than those specified in the procedure:
Engineering review of this matter determined that the 4.0 inches water column differential pressure sp~cified in the procedure was in itself incorrect. Engineering subsequently determined that the correct ~est pressure was 4.65 inches water column. Engineering Evaluation S-C-SC-MEE-1212 evaluated the actual test data, and extrapolated the test results to an initial differential pressure of 5.0 inches wat~r column. The results of the extrapolation remained below *the 50 cfm unfiltered inleakage assumed in the Control Room dose calculation.
. NOV example 4: Test initial and final times were not recorded: Engineering evaluated this matter and determined that since the actual test duration was approximately 10 seconds, rather than the anticipated 1 5 minutes, initial and final times were not essential for this test. The test duration, in seconds, was recorded and used to perform the calculations. Engineering Evaluation S-C-SC-MEE-1212 recalculated the leakage values using the measured test duration and found the results to be acceptabl NOV example 5: 1 EC-3505, Package 1. STP-4, Revision 3, Step 5.6.1 regumng review of test data by the test engineer was incorrectly deleted: A review of the test data by a Level Ill test engineer was conducted as part of the package final
closure in June 1997. A signature to document this review was added by administrative change at the time of final package closur Conclusions Based on the corrective actions taken by PSE&G and documented in the PIRs, the inspector determined that the deficiencies cited in the NOV were adequately resolved. In addition, the inspector found that the deficiencies identified by the TRB were also adequately addressed. The inspector noted that several of the PIRs remained open at the end of the inspection, including a Level 1 PIR issued April 15, 1997. These PIRs will require additional* review when they are finally close This violation is close E (Closed) Restart Issue P22. Integrated Test Program, Unit 2 Background PSE&G proposed, in mid-1996; to perform an Integrated Test Program for starting up the Salem Units from the extended outage. The Integrated Test Program consisted of a combination of post-modification, surveillance, and special tests to ensure the facility conformed to the design. Testing was planned for cold shutdown, hot shutdown, low power, and power ascension. The scope and content of the test program, as well as the controlling documents, was reviewed and found acceptable in NRC IR 50-311196-21. That inspection report also identified deficiencies in the format and content of post-modification test procedures for the Control Room Area Ventilation system. Subsequently, both PSE&G and NRC identified additional examples of procedural inadequacies, as documented in IR 50-272 & 31.1 /97-06. IR 97-06 also identified instances where the test procedures for Control Room Ventilation were not properly conducte Observations and Findings In response to the NOV issued with IR 50-311/96-21, PSE&G conducted a review of all the post-modification test procedures for Control Room Ventilation, and a representative sample of procedures for other non-ventilation systems. Several additional procedure deficiencies were identified and resolved. PSE&G also took steps to strengthen the procedure generation process. These measures included:
TRB review of all power ascension test procedures prior to implementation, and the governing procedure for generating post-modification test procedures has been revise During the inspection documented in IR 50-311197-06, the NRC identified instances where testing was completed and closed out without the acceptance criteria being met, and several occasions where the test documentation showed that testing was not conducted in accordance with the appproved test procedure. In response to the NOV, PSE&G directed the TRB to review the test results for all completed testin *
TRB review of completed testing identified a number of instances, in addition to those noted by NRC, where testing was not performed as specified by the procedures. Test personnel were retrained on the significance and importance of test prerequisites and initial conditions, and the need to implement procedure *
changes if test methodology is altered. This training has continued through the end of the inspection perio PSE&G implemented additional changes in order to increase the management oversight of testing. One change was to relocate the installation and test fonction from the Design Engineering organization to the Mechanical Maintenance organization. This relocation included splitting the installation and construction function of the projects group from the testing function. Each of these new projects groups under Mechanical Maintenance also has its own supervisor. The person recruited for the new Projects Testing Supervisor position has extensive startup and testing experienc Conclusions While problems with testing continue to be identified, the inspectors concluded that test performance improvements have been, and are being made. Test personnel are now identifying deficiencies during data reviews prior to test completion signoff. In addition, the reviews by Projects Test Group supervisors and the TRB are ensuring that testing was properly performed, and that test acceptance criteria have been me Based on the performance improvements noted, and the increased management attention to testing, the inspectors concluded that the Integrated Test Program is adequate to support the startup of Salem Unit Startup Issue P22 for Unit 2 is close V. Management Meetings X1 Exit Meeting Summary The inspectors pre$ented the inspection results to members of PSE&G management and technical staff at the conclusion of the inspection on June 26, 1997. PSE&G acknowledged, and did not challenge, the findings presented at that tim Some of the information reviewed during the inspection was marked as proprietary information. Those materials were returned to PSE&G at the end of the inspection.
PARTIAL LIST OF PERSONS CONTACTED Public Service Electric and Gas Company M. Rencheck, Director, Salem Engineering E. Nagy, Startup Manager J. Broadwater, Testing Supervisor R. Chen, Project Engineer D. Wolverton, System Manager J. Higgins, Test Engineer D. Best, Project Engineer S. Morisky, Test Engineer C. Farley, Test Engineer E. Villar, Licensing Engineer B. Thomas, Licensing Engineer U.S. Nuclear Regulatory Commission C. Marschall, Senior Resident Inspector R. Lorson, Resident Inspector State of New Jersey, Bureau of Nuclear Engineering D. Vann, Nuclear Engineer 37828 70304 70400 72301 72400 71707 OPENED LIST OF INSPECTION PROCEDURES USED lnstall_ation and.Testing of Modifications Engineered Safety Features Test
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Preoperational Test Results Evaluation Startup Test Results Evaluation Overall Startup Test Program Plant Operations LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED NCV 50-311/97-10-01 Control Room Ventilation Post-Modification Test Procedure Inadequacies NCV 50-311/97-10-02 NCV 50-272/97-10-03 DISCUSSED VIO 50-311/96-21-01 Control Room Ventilation Post-Modification Test Performance Inadequacies Diesel Generator Post-Modification Test Performance Inadequacie Control Room Ventilation Test Procedure Inadequacies
AC AR CAA CS CAV CFCU CFM CR CREV DCP deg F EACS EDG GL IR kV MCR NBU NOV NRC PSE&G RP SCFM SGS STP SW TRB VIO
LIST OF ACRONYMS USED Alternating Current Action Request Control Area Air Conditioning Control Area Ventilation Containment Fan Coil Unit Cubic Feet per Minute Condition Report Control Room Emergency Ventilation Design Change Package Degrees Fahrenheit Emergency Air Conditioning System Emergency Diesel Generator NRC Generic Letter
Inspection Report
kilo-Volt
Modifications/Concerns Resolution
Nuclear Business Unit
Nuclear Regulatory Commission
Public Service Electric and Gas Company
Recorder Panel
Standard Cubic Feet per Minute
Salem Generating Station
Special Test Procedure
Test Review Board
Violation