IR 05000293/1987041
| ML20236R891 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/19/1987 |
| From: | Bissett P, Blumberg N, Briggs L, Marilyn Evans, Oliveira W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20236R887 | List: |
| References | |
| 50-293-87-41, NUDOCS 8711240088 | |
| Download: ML20236R891 (14) | |
Text
{{#Wiki_filter:yab ,1 ,4 ~ - - ~ GF <
- . 6 (i M
y,R < ; ' y, W M' ,., ., 7, , q; j - k jp.i, j < , p;w - > , y , ' ' .U.S... NUCLEAR REGULATORY COMMISSION > , < ,r
REGION I
I r l '" o - Report No. (50-293/87-41-q ' e{ . ' Docket No.:~50-293 ' y , V License No, 'OPR-35 ' T Licenseei : Boston Edison' Company l ' 800 Boyleston Street - , '$, sBoston, MA 02199 ' ' [" [ Facility'Name: ' Pilgrim Nuclear Power Station- ' 'j' ' 'v , . , . . Inspection Ati-Plymouth,: Massachusetts ' , < , e . Inspection Conducted: September 14-18, 1987
f -- sq ] ~ '
- Inspectors:
. 4/r /e//5 77 . , . . Bissett, Senior Operations Engineer, DRS ' dataf g . - -, ,.' n ^ . L. Briggs,~S r' Operations Engineer, DRS date ' ' '
w NM /D//fl67 M. Evans,: Operations Engineer, DRS.
' datd ,, , . / fx NbC/f7 .'0Tiveira,1eactor Engineer, DRS 'date' [O!/I[F7 Approved by: -
I
N. Blumberg, Chip't / 'date
Operational: Programs Section,A)B, DRS
- , .
.. Inspection Summary: Routine, Un' announced Inspection on September 14-18, 1987 ! .. V:( ' (Report No. 50-293/87-41)- ) - LAreas-Inspected: Routine, unannounced inspection of licensee actions on ?' previous-inspection' findings, the surveillance testing and calibration j , program, measuring and test equipment, preoperational testing and Quality j l, ' ,: Assurance / Quality Control interfaces.
The' inspection was performed on site by fouriregion-based inspectors, , n 3" v ' . Results: No violations or deviations were identified.
V.
871124000s 871117 F PDRc ADOCK 05000293? bb, - G PDR O bO2
- _ _ _ _ - _ - _ - _ - - _. - - _ _ _ _ _ _ _ _. _ _ _ _. - - - - _ - - - _ - _ _ _ i - . -.. . DETAILS 1.0 Persons Contacted Persons contacted'are identified in attachment A to this report.
[~} 2.0 Licensee Action On Previous Inspection Findings l 2.1 (Closed) Violation (293/87-04-02) Failure to evaluate and document the. validity of previous tests for which measuring and test equipment (M&TE) was used and subsequently found to be out-of-calibration (00C).
The inspector reviewed and discussed with both the Instrumentation and Control (I&C) Engineer and the Station Services Group Leader, ! those actions that were taken to correct the identified problem.
The inspector. verified, by a records review, that all previously identi-fied 00C instances had been evaluated and documented.
It was also noted that specific training sessions had been conducted in regard to 00C evaluations, and that these evaluations are now being completed within one week from the time the 00C condition is identified. Also, 'the stations M&TE procedure was revised to specify the responsibility
for the conduct of these evaluations. The Station Services Group has developed a Non Conformance Notice Log which readily identifies and tracks 00C instruments and their associated evaluations. Based upon the above review, this item is closed.
2.2 (Closed) Violation (293/87-04-03).
Refueling Bridge Preoperational Test (TP No,'86-127) was performed without making appropriate tech- .nical changes to correct procedural errors concerning refueling bridge position numbers and without obtaining the required approvals prior to implementation.
The inspector reviewed procedure change notice (PCN) No. TP87-013 and verified that the refueling bridge preoperational test procedure had been properly revised on January 15, 1987 and that the applicable procedure steps were performed again on January 19, 1987.
In addition, the inspector noted that procedure TP No. 86-127 was revised in its entirety and reissued on January 28, 1987. Cased upon the above review, this item is closed.
2.3 (Closed) Followup Item (293/85-03-06) Licensee to review applicable I&C surveillance tests and determine their technical basis.
Discus-sions with the NRC resident inspector indicated that this item is effectively being reviewed under open item 293/85-03-04.
For this reason, item 293/85-03-06 is administrative 1y closed and will be reviewed under 293/85-03-04.
2.4 (0 pen) Unresolved Item (293/86-21-03) Licensee to review completeness and adequacy of Technical Specification Surveillance Procedures for logic system functional tests (LSFT).
s . . _ - _ - - - _ - _ - - _ _ - _ _ _ - - - - - - - - _ _ _. - - _ _ _ - - - - - - - _ _ - - - - - - - - -. - - - - - - - - - - - - - - -. - - - - - - - - - -. - - - - - -
q7 jf _ p .; . y , .c I .c
. q.
' The inspector reviewed licensee actions to date regarding evalua-
e tion of.the adequacy of LSFT (see discussion, paragraph 4.2).
No " unacceptable conditions were identified.
This item will remain open pending further review of revised LSFT surveillance procedures.
>
2.5 (0 pen) Unresolved' Item (293/86-21-04) Licensee to evaluate testing - "y methodology utilized to meet the intent of simulated automatic actuation (SAA) testing required by Technical Specifications (TS).
g V; ' -The inspector views that simulated integrated system initiation, with , 'the exception of injection, as necessary to meet the intent of SAA testing. The' licensee's methodology utilizes a series of overlapping e f' logic system. functional tests to meet the TS requirement for SAA . testing. 'The item will remain open pending further review and . discussion.by the licensee and the NRC.
2.6.(Closed) Violation.(293/87-04-04) Licensee failed to establish an .
- administrative procedure that controlled the site's overall test
~ program. This violation applied to programs for specific in place periodic testing such as Technical Specification Surveillance tets, > . post' maintenance tets, and post modification tests.
Implementation of testing was~not addressed in the inspection.
On May 1, 1987, licensee representatives met with NRC management to obtain clarification of those elements' associated with this < . , violation. 'BECO. management felt that.they had not effectively presented.to the inspector, during inspection 293/87-04, those ' administrative programs and associated procedures already in place that addressed 10 CFR 50, Appendix B, Criterion XI " Test Control" ~ requirements.
- Subsequent to this meeting, by letter, dated June 8, 1987, the licensee:took exception to this violation. The attachment to the June 8,.1987 letter addressed those concerns identified by the inspector.and presented-corresponding programs and procedures that they believed met the requirements of 10 CFR 50, Appendix B, Criterion XI, the BECO Quality Assurance Manual and ANSI 18.7-1976.
-During this inspection, the inspector discussed with various licensee representatives and reviewed specific administrative procedures that were specified in their response as adequately , a'ddressing the inspector's concerns, which included: ! Overall mechanisms for control of specific test programs - ,, List personnel qualifications - -Test prerequisites ~ - uReview of test results - Test instruments - j Test acceptance criteria -
Test procedure format - , l.
2___ _
m. - - - p +'
- o
^'
- ~?.,.
- ..
. i i st The inspector determined, following this review, that control of testing is adeauately defined and that appropriate procedures are currently in place that provide control of specific test programs.
Based upon the above review, violation 293/87-04-04 is withdrawn.
F Approximately ten procedures were presented to the inspector, each , addressing some of the areas specified in the violation.
Following review of these procedures, the inspector determined, that although some what disjointed, the procedures when taken collectively, meet regulatory requirements.
Each item in the violation is addressed in the procedures.
Based upon the above review violation B in Inspection Report 50-293/87-04 (NRC open items 293/87-04-04) is withdrawn.
3.0 Surveillance Testing Program an 3.' 1 Scope and Criteria The licensee's surveillance test program was reviewed for conformance to the following requirements: 10 CFR 50, Appendix B --
' ' Pilgrim Nuclear Power Station (PNPS) Technical Specifications -- (T.S.),Section4,SurveillanceTests Regulatory. Guide 1.33, Quality Assurance Program (Operation) -- ANSI N18.7-1976,. Administrative Control and Quality Assurance --- for the Operational Phase of Nuclear Power Plants a PNPS, Final Safety Analysis Report (FSAR) -- 7g , .The licensee's master surveillance schedule is entitled " Master Surveillance-Tracking Program" (MSTP). Administrative controls .,' were evaluated to assere that the MSTP was consistent with the preceding requirements.
The key procedure for defining and administering the MSTP is Procedure.No. 1.8, Master Surveillance Tracking Program, Revision 5.
The procedure is being revised to reflect the new MSTP that has been developed. The new MSTP is currently operating in parallel with the existing MSTP and will be fully implemented in late November 1987.
In addition to as-sessing the documented MSTP effort, the inspector also observed i three surveillance activities being conducted by electricians
and instrument and control (I&C) technicians.
. L 2 __ _ _ _ = _ _ _. - - - _--__-_.
- _ - _ - _ - - - - _ _ _ - _ _ - _ _ _ _ _ _ _ _ - _ - - _ _ _ _ _ - _ - - _ _ _ - - _ _ _ _ - _ -
%t i : VI, w > , , 4,w-ci w Q};lff;d *
. NH+ W m $h , s . s , - > J ! ' ,g >e1
if; g ,7 .-, q- -1': 1, ,
G .
- E.
...., a
- 3121 Review / Implementation
> y .. o, V, The;NRC inspectors. discussed.with the Technical Section Manager the ' . ,
N #" Ltransfer;ofJthsMSTP responsibility from the Project Control' Group , A- .V Lto Lthe'.Technicali Section.' AlsoJdiscussed was.the role the'new MSTP 4W,'; ' .will play 11nithe. licensee's commitment to have.a centralized, clearly- ' A P
- defined and/ forward 11ooking surveillance' program.
Discussions.were /n '
- also: held.with'thel Deputy to the-Vice. President-Nuclear Engineering
' , gJ who is overseeing lthe MSTP effort. The. items covered included: .) , , s
, , "TheLqualificationslof tthel individuals responsible for the ' , . ',? Jnew MSTP-- r
, .. ~-? qThelresponsibilities of the. support groups .' l ' - , -,,
- . _, n,c
- . c-;
- ThEstatus'offthe;newMSTP)
, , ' " ' mj ,r .1 ,og - iThe introduction'o'fi he new MSTP.was one'of several corrective t . actions:takenLby:the' licensee to' improve.their. surveillance program.
QThe: previous!MSTP was: (1) difficult to use,: Update...and manage; M M+ J(2) unaccountableTfor; plant conditions', scheduling. multiple component'
- testsp and; identifying'real? problems;'and-(3) not credible since its-
- .
,f idata base had not been verified.. With guidelines from INPD TS_410 , " ' J" Surveillance and Periodic' Task Scheduling Program," a'nd assistance , ifrom"aLc'omputer/ program /and' services. contractor, the licensee began
[ '.to develop ~ainew MSTP. :In addition to. correcting the problems in the l@ existing MSTPU the new program will. incorporate non TS." additional ' safety. margin"l surveillance, and be' capable of integrating other r '@ " ' elated testing 1such as preventive maintenance (PM), post-maintenance r a - ,i ' , testing.'(PMT), and inservice testing (IST).
, , m s ,' jt w Ths-Surveillance CoordinatorEista senior. engineer whose previous
w , experience includes the development of 'a program similar to the-MSTP ,: - y
.for a'NSSS contractor.
The: Surveillance-Coordinator has the overall ' f l responsibility for implementing and maintaining the new MSTP.
He M . reports to the Technical.Section Manager via'his Systems Group Leader.
- l'
- ?the ponding' changes to. Procedure'No. 1.8; the preparation of the new 'The: Surveillance Coordinator reviewed and discussed with the inspector,
- ,;
Ltask cards; and demonstrated with the computer some of-the features of &< . , g , the.new MSTP,'e.g., impact of extending surveillance frequency up to
the~2S% allowable time limit. extension permitted by TS.
f > , _ b ' , . W 'The4 Surveillance Coordinator is technically supported by the system t, ' engineers within'the Technical Section. Under the direction of the ' , i Surveillance. Coordinator,ithe Project Control Group will. con- ' ' 9."
tinue to, provide services:to process computer software since the ' ~
- forms in the
- existing MSTP are being retained under the new MSTP.
+ t ,, '* . The-~ additional forms required by the new MSTP are the task card and .. the_ Failure to Comply Notice. Other Section Managers and Group Leaders will:also: continue to support the MSTP effort including re-viewing:and~' responding to task card inquiries and Failure to Comply ' Notices-- ' l '
\\ ! - ~ k } l s .l t
w...
w. , pn . (UQP;g.g 9 t 9 :, _ t - Ppp y M*
, p/ s' , t ' , @ d
' ys, g 1 y 4 (fl ' y .< ' Y ('I, . m ,
aTheistatus of the MSTP affort was reviewed by the inspector.
As
. previously: mentioned M3TP: Procedure: No.1.8,. Revision 5, current-
-. " ~ ly 1.n:effect,;is intthecprocess of being-revised. Management and "' ' , . J% ~ ' ~ Supervision' expect;the'new MSTP to' greatly enhance the surveillance ' g" program., Milestones achieved'thus far, include:. data base valida-t
k Ltion by...the_ contractor; major update of the logic function testing in J . W.
progress;-. initialtreview of task cards: by Operations; and. identifying . ' > - y .w i ?what'isineeded to~ accomplish ~a test, including manpower requirements.
W ., ~ . ,' [g. iTheLinspector al.so. observed the foll.owing surveillance:
, y "v' i~ ~ .
- A once'per cycle / refueling surveillance conducted in accordance _ _
W '- - with Procedure No-. 3.M.3-1, Revision ~15, "AS/A6 Buses 4KV Pro- ' ( g'
- Verification." A caution l statement in the procedure required.
l , ,# ' ttective Relay Calibration / Functional Test and-Annunciator ,< , ', the Bus SA breaker to'be in..the " opened off" position when . pKy" s^ (racking down the startup--transfer breaker to avoid starting the - - , ,
- g L
emergency diesel rgenerator (EDG) 'A' on an.undervoltage signal.
j W The'EDG however started with the Bus'5A breaker in the " opened ~ > s , % ~ .'off"Lposition..The cause of the problem was that the' cell' w, , breaker position" switch changed its' position when' the startup , ! transfer breaker was racked.down.
The procedure was corrected
- .
- and. approved, Land-the surveillance continued.
' 'l
- A. semiannual surveillance' conducted in accordance with
- q
- -. , Procedure No. 8.M.2-l' 5.8.4,' Revision' 15, " Logic System j ' ' . ' Functional Test of System 'B' Standby Gas Treatment Initiation, i ', , , - W . Reactor: Building Isolation, and-Outboard Drywell Isolation > ,
- Valves." In preparation for the surveillance, the Instrument
' <
, %" ~
- and Control (I&C) technicians'noted a green and white test tag
'l on Panel 7f(C904)'. They:did not proceed until the " owner" of . ' ,
- the' tag-provided.them with a.' signed approval to operate the
. M itagged croonent. :TheLinspector followed up on this action by > ,' i ireviewing N cedure No; 1.4.5, Revision 21, "PNPS Tagging j f, cProcedure.".The :I&C technicians were in compliance with the j procedure.
In another case, paragraph 11.a. (3) listed an amber , '
- < E light at Panel C-7 for fan VEX 210B. There is no amber light on thel panel for' fan VEX 2108. This-paragraph was corrected during
) { this. inspection in revision.16 of Procedure No. 8.M.2-1.5.8.4.
. ,
- A quarterly-surveillance conducted in accordance with Procedure l
-
, . 3:t
- No.-8.M.1.32.2, Revision 1, " Analog Trip System - Trip Unit j
/- Calibration - Cabinet C2228-A2."
In paragraph 5.h, the I&C !
g 1l-technician removed fuse F2 and verified that the relay was j, Jde-energized.. In paragraph 5.j, the I&C technician reinserted r y ;ji the F2 fuse'and the fuse failed. A maintenance request j j (MR 87-495) was prepared and processed.
Since the fuse was an ' ^ , !
EQ item, a Quality Control (QC) inspector followed the request . W for a new fuse and the subsequent installation of the fuse.
q , ' .No-violations or deviations were observed.
w > , < y l 3, ' e e.
_ _
y M g ] y t ]
' k. %.? g , 7, 7. " O y e - . - J hh r y_ y , g pf. 3 ... c ~. g
, . _, ll .,..,, >
t j ,* <M & 13;3 Findings: i y "g
- >%
JThe problems encountered in each of the: surveillance discussed in , A y' -- paragraph:3.2 wereLresolved and: corrected inta. conservative manner, f
- and documented in accordance with the proc'edurall requirements..The
' ,
- personnel involved in thefsurveillances were knowledgeable of the-s, e
Ltechnicaly.and procedural; requirements- ' . y <, c [^> ' The inipect.or reviewed a'nd discussed the draft of the new MSTP pro- ?> cedure.'with several111cens'ee personnel.
The: licensee acknowledged q, " 'andfagreed,to.reviewithe<following concerns: . W: w , @ A The!first line in paragraph 5.4.11= states that. the Surveillance ' , , . L ', '
- Coordinator'should " Coordinate periodic surveillance audits."
q, m Quality' Assurance, not the Surveillance Coordinator is respon- ' ,
- sible' forburveillance? audits.. The. Surveillance Coordinator may , M however,:bdiresponsible:for conducting periodic reviews.
, ' w' 'E ' Changes tossurveillances are to be reviewed by.the systems ' -
- engineers. -Paragraph IV.H.3 in the existing procedure-allowed
. ' ' "
- changes, such as incorrect intervals (frequencies),' to be made
< f,,s y :without>rev.iewing the impact on the-.related systems.
, [ Noviolationordepfationswereobserved, ' L3.4l Conclusions-e4 ,
Managementihas p'rovided-the resources, time, and qualified personnel ' .to. develop ~a:new centralized, properly defined and computerized MSTP.
After?its implementation'in. late November 1987, continued management ,, ,
'atte'ntion'is warranted to ensure desired. improvements are realized.
- s
rEqually:important is'the incorporation;of the. Preventive Maintenance (PM),. Post, Maintenance. Testing (PMT), and the. Inservice Testing (IST) ~ programs into the MSTP, . 'L4.0LSurveillanceProcedures' , ?4;1f Scope IDuring'NRC inspection 50-293/86-21, the' inspector identified a concern ,,M> . involving;the completeness'and adequacy of Technical Specifications ' A '(TS). surveillance procedures;for HPCI logic system functional testing y< 1(see paragraph 2,4, unresolved item 86-21-03).
The licensee re- ~ sponded to this 'oncerniin BECO Letter #86-185 (December 5, 1986) and @
c agreed that their surveillance procedures did not fully test system > i.
- logic features.
The licensee stated that they would review other N< . ECCS logic system functional' test procedures for similar areas of concern' prior to plant mode change requiring these systems to be a~ operable. 'During the current-inspection, the inspector reviewed the x licensee's corrective actions regarding logic system functional tests-(LSFT).
, ,e ..........-{* _ _ _ _ , H o-r ' .
m,.y1 ..
- e
- - - - - - - - - - - - - - - - - - - - - - - , k h h-! 5 %--
' f l & _ l"" - ' ~ ^ w gy;n,p' e ' L k h' L8 %, ' g; f.3
" ' '; '
' 14.2ll Review
s . y fThecinspector discussed the status of the licensee's review of.LSFT ' f 7-w
- With ailicensee representative.
The representative stated that a ' > ~ majority. of. the; review effort has been conducted by a contractor and f.
' is n' earing. completion. :The review included identification and C
evaluation-of all' LSFT procedures required-to meet TS ' requirements.
~ ' sThe' evaluation. process' included' highlighting of appropriate , i lectrical elementary / scheme drawings to' verify that logic flow paths % e . 'between sensing. device (s) and activated. device (s) are-tested in the ' ' ' surveillance procedure; currently in use. The purpose of.this. review
< was to. establish whether or not the current test procedures adequately > s y m itestLthe' equipment and that:the test interval is less than or equal , . . to'.the test. interval' required by--TS; Changes are being made to ,
- '
applicable surveillance procedures to incorporate deficiencies and e s % . discrepancies ~ identified by-the above review (along with those.
J Lidentified~ duringL previous. licensee,' NRC and INPO reviews and-system modifications). -Procedure walkdowns'.are being conducted to ensure ithe' resolutions are' technically. feasible and that proposed changes - ' r%.; ' are' physically amenable.for: performance prior to final. incorporation
of.the changes'to the procedures.
. p? -The licensee representative stated that to date all LSFT procedures-
. .
> ~ . . . p' > ' ' required have' been identified and' evaluated.
Resolution of '
/ identified deficiencies and discrepancies is presently. ongoing,.with- ' Lpriority being given-to procedures required for fuel reload.
' w . ~ -The{ inspector reviewed two surveillance-test-procedures required for %. fuel reload:
- - ?
8.M.2-1.5.8.3, " Logic System Functional Test of System ' A' 4.
' Standby Gas; Treatment (SBGT) Initiation, Reactor Building , -Isolation.- and Inboard Drywell' Isolation Valves ( Atmospheric Control l Valves)"~
8.M.2-2;10.8.3, " Diesel Generator (DG) ' A' Initiation By Core - Spray Logic" [ ~ ' The:LSFTzfor the SBGT system was reviewed to verify that the testing conducted agreed with system logic per "SBGT System Modification" u , , PDC-86-70. The inspector found no discrepancies in the' logic testing f , , , g during.this review'. j " N. '
,
- The. DG "A" surveillance procedure' was reviewed to verify that deficien-
- ..
cies: identified during the LSFT review of DG surveillance testing had ~, , .been properly incorporated into the current surveillance test procedure.
However,:the inspector noted that the procedure did not include testing
~to show that the DG Shutdown Relay could only be energized by the ! - .0verspeed Relay with an Emergency Start signal present. The inspector .] . , discussed this concern with a licensee representative.
The representa-F.. # tive acknowledged the inspector's concern and committed to include the testing int surveillance procedure 8.M.2-2.10.8.3.
The inspector had no
- further questions.
" t "p.' L.
+
wwn x - - - - -- - - - - - - - - -
- - -
k%h.- " M[ NXg ' >
, , %. , s , l ', 00:l ' y,<,< + (77 > f b ;
- 9 p" i;.&
S !
y
- ,'y
,
h.
,u , f '. , t.x % ' 4. 3 ? 'Fi nd"i ng s ' " INo violations' or. deviations were " identified.
5.0 EMeas'Urement and Test Equipment' , , g- - 5]:ScopeiandCriteria.
M . Refer toiparagraph:3.1.
i
- 5;2'!Phogram' Review / Implementation
' , ,
'
Th'eiinspector held; discussions:with individuals designated to adminiT-ter:and control the site's measuring and test' equipment (M&TE) program.
- , g . Control of this program is designated. in Procedure _1.3.36 " Measurement , 'N and: Test Equipment,'_' Revision 3.
A review of this procedure governing g'.. ~ ' .the contro11of M&TE was conducted to verify that the program _was being , 7~, ' ' implemented as'. intended. EAlso reviewed were those changes being made to upgradeLthe M&TE program. These planned improvements are.part of "fv., '
- the. licensee's~recently developed Material. Condition Improvement Action fPlant(MCIAP). 'Specifically, Section M of the.MCIAP addresses the need
,
- for.the; control', Calibration-and maintenance of M&TE, including such
. w, aspects as staffing,. training and qualification, organizational respon-
sib 111 ties,0 inventory centralization,. computerization, etc.
, \\; To'date the li.censee has. accomplished the following: ' g /*t Four additional contract personnel have been hired to speci- ' .fically: control the issuance.and storage of M&TE.
- -
All M&TE on site has beencinventoried and uniquely identified.
- All.! pertinent'information for 1492 M&TE items has been entered a
w
- into an' automated data base system.
- During th'is inspection,.' personnel were evaluating the space
~.' + ' requirements _needed for;the eventual centralization of all site M&TE.
E5.3 Findings , ' No: violations or deviations were identified. The inspector noted tthat desired actions have been initiated to improve the control of ' , the M&TElarea,--however, this control'is essentially conducted manual-
- 1y. ;A " continuing.' action item"'of the Material Condition Improvement LAction Plan (MCIAP) calls for the installation of computer software
~ - - ' i and. hardware.that.will replace those controls that are manually , performed at present. A _ lack of manpower to effectively utilize the imanual.' controls previously in. place eventually resulted in a number L ~ .of identified problems in the M&TE program.
The inspector noted that " continued management attention is needed in the M&TE area to preclude ..the: reoccurrence of the same problems. This would include fulfill- . ment of " continuing action items" as detailed in the MCIAP.
The ! , F inspector had no further questions.
' y.
- ) I ] e xj$ l
- r
> > ,.m ....
p,~ . ",,\\ ' ~- ; ~ 3; . ' b p > pi , h.$ W , _ '
- c up.
. *a - , , D . L,:
-
s pp Ei _, f g
- . -
p 3y 3.-
(, (6.0 osYModification!PreoperationalTest(PMPT)ProcedureResultsReview ' 16;1:? Scope: , , , ~ 1 The d'as-run copies of. the test. procedures were reviewed to evaluate '
- acceptance" criteria,nrecorded: conduct of the test, 'QA/QC inspection
,, f' records,' restoration of system to normal after test completion, indepen-- <, - @ ', J dentsverification of critical steps or' parameters' and identification of ' ' lpersonnelLconducting the_ test In addition,.any. Plant: Design Change p ,y s.
- (PDC)sthat had not been previously reviewed. that
- was associated with 'a -
p PMPT/ wasLalso ' reviewed to determine specific. testing. requirements.
' ' ,
- ~
.TheLeompleted PMPT procedures listed below were reviewed during this Linspection to verify.that adequate. testing had been conducted to satisfy.
'
'% p regulatoryrguidance, licensee commitments and PDC requirements.
f J' -PDC 85-14, Reactor Building ~ Secondary Containment Isolation >>
, % ' ',, L^' Damper-Replacement. .
k7" , LTest Procedure (TP) 87-26, Pre-OperationalLTest of Secondary -: c-Containment Dampers, RevisionLl' + ' '
- TP87-100, Leak' Rate Test"for Secondary Containment Dampers
.- Installed;Per-. PDC 85-14 a ' - ' ' iTP87-128,-Pre-0perational' Test of Standby Gas Treatment System
- "
y
- Modification Per PDC 86-70, Revision 1, 2 and 3 l1 6.21 Review / Implementation k
- 6.2.1 PDC 85-14;'TP87-26'and TP87-100 e
- s a;. ' ' ' ' This modification ~ replaced all secondary containment dampers (18) . '
- '
with~new high' quality dampers. ~Each aper was replaced as a unit, pi.e. damper,; actuators and position indication limit switches.
< , , No: logic changes were involved.
Subsequent testing (TP87-26) g- , , einvolved stroke. timing and position indication functional tests.
S , - All. valve stroke times were within acceptan'ce limits with the longest; closing: time being 2.92' seconds.
Leak testing was ' conducted under TP87-100 with fully acceptable results.
j. ,
_ 6.2.2 TP87-128' ' E . This' procedure was. discussed in NRC Inspection Report 50-293/87-33.
' , - During this. inspection'the completed procedure results were reviewed and f_ound acceptable.
The above; tests were discussed with-the licensee at various times throughoutithe inspection to resolve questions concerning test conduct
, , H 'and test results. All questions were satisfactorily resolved by tne . ~ licensee.
- , N . . ' , ..3.. -... _ ' _ _ _ _ _ _ _ _ _ _ _ _ _ _.. _ _ _ _ _
g_ .... .- ., '
+ . , w
' ! ' 6.3 Findings-No' violations or deviations were identified during the above review.
'
- 7.0 -Quality Assurance / Quality Control Interface A Quality Assu'rance (QA) group is represented on site, along with Quality Control (QC) personnel. These. groups are thus able to effectively monitor ongoing station activities.
Discussions were held with the site QA and QC Group Leaders and the corporate (off-site) QA Group Leader to evaluate their' involvement with those programs reviewed during this inspection.
It was noted that the site QA group performs periodic surveillance and the h . corporate QA' group performs audits of various site activities, including-Technical Specification Surveillance.
The inspectors reviewed 14 QA Surveillance Reports and three QA audits thar,' addressed'the licensee's surveillance program. The review of QA completed surveillance reports covered various areas of plant activities conducted during the-past 18 months (areas covered are listed in Attachment B)..The Surveillance Report packages reviewed included surveillance checklists. QA recommendations,.and deficiency reports.
The QA uudits reviewed were comprehensive and the findings were resolved 'in a timely manner.
During this inspection, an annual Technical Specification (TS) audit was in progress which will cover about 25% of all ! the TS requirements.
The. audit team included a technical expert on the l Master Surveillance Test Program (MSTP). This individual stated that the new'MSTP is a -significant improvement over the existing MSTP.
The QC inspector who followed up.on replacement of the F2 fuse during the Analog Trip. System surveillance (discussed in paragraph 3.2) was knowledgeable of all technical and procedural requirements associated '
with this surveillance.
.I . y No violations or deviations were identified during the above review.
++ 8.0 Plant-Tours The inspectors toured various areas of the facility to observe work in progress, housekeeping, cleanliness controls and status of outage activities.
No unacceptable conditions were noted.
' h , l](I jf u - h h L
. . .ip.
NV; ' ..
w / 9.0 Exit Meeting Licensee management was informed of the scope and purpose of the inspection ., at an~ entrance meeting conducted on Septemoer 14, 1987.
The findings of the inspection were periodically discussed with licensee representatives during 'the' course of the inspection. An exit meeting was conducted on September 18, 1987 (see. Attachment A.for list of attendees) to summarize the scope and findings of the inspection.
At no time during the inspection was written material provided to the licensee by!the inspectors. Also, the licensee did not indicate that any proprietary information was contained within the scope of this inspection.
- ,
, t . . =. L ,] < l , l
- .
L.
.
l <
W== w.,s L) , , y-g:'.g' p,,, - ! . i , J. T.
f@M.j, "f</br>.J</br>*</br>a H</br>U</br>{[mja;-</br>'</br>y p ~ > ;c,</br>d f[ ;ij</br>'</br>, 4 %</br>,7 5..k$ j</br>' ATTACHMENT A</br>'</br>^</br>'</br>.. y';.</br>.? Persons Contacted</br>!i gs s</br>'</br>W; >,</br>' Bossn: Edison Company</br>'</br>M \\}</br>*Mb Akhta'r,, Group Leader, Modifications Management</br>"~</br>*L'. Beckwith,1 Compliance. Engineer,: Nuclear Engineering' Department 3,</br>1J fTu Beneduci,; Senior. Modification Engineer jg it.,</br>*Si Bibo,' Audit. Group' Leader, QA-</br>'</br>*M.;Brosee; Outage Manager.</br></br><</br>*,</br>*W.;Clancy,. Systems Group-Leader.</br>..</br>.</br>,</br>'</br>*F. Famulari, Group " contains a listed "[" character as part of the property label and has therefore been classified as invalid.. &W U j.
, /.m i .g i i i ! o _ _ .I
bb) ,1 . ' ' , m- , % s',~,a _ _ ~.., '. 3r, g., n.' ; '. 6- ,. .,
ATTACHMENT B.
Quality' Assurance Surveillance Reports . Surveillance No.. 87-1.'2-1, Standby. Gas. Treatment 87-1.2-2, Suppression Pool' Water Level Calibration 87-1.2-3, Pre-Operational Test of the Alternate Shutdown System.
r , 87-1.2-4, Emergency D/G Dry Chemical Fire Protection System ' ' 87-1.2-5, RWCU High Flow Functional and Calibration.
. 87-1.2-6, Control Room Environmental Functional Test 87-1.2-7, Manual Start and Loading of.D/Gs 86-1.2-1,.'0' SW Pump IST , 86-1.2-2, Turbine Control Fast Closure .86-1.2-3, Control Rod Block System Logic Test 86-1.2-4, Reactor Water Sampling' 86-1.2-6, Reactor Water Level Safeguard Systems . 86-112-7, ATWS Functional Test - __ - 2 }}