IR 05000315/1986027

Insp Repts 50-315/86-27 & 50-316/86-27 on 860707-11. Violation Noted:Failure to Adequately Test ESF Response Time in Unit 1 Steam Generator Water Level hi-hi Level Turbine Trip Reactor Trip Test

ML20206N495
Person / Time
Site:	Cook
Issue date:	08/20/1986
From:	Darrin Butler, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206N487	List: IR 05000315/1986027 ML20206N483 ML20206N490
References
50-315-86-27, 50-316-86-27, NUDOCS 8608260304
Download: ML20206N495 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-315/86027(DRS); 50-316/86027(DRS)

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Docket Nos. 50-315; 50-316 Licenses No. DPR-58; DPR-74 Licensee: American Electric Power Service Corporation Indiana and Michigan Power Company 1 Riverside Plaza Columbus, Ohio 43216 Facility Name: D. C. Cook Nuclear Plant, Units 1 and 2 Inspection At: D. C. Cook Site, Bridgman, Michigan Inspection Conducted: July 7-11, 1986 Inspector: David S. Butler b!20!b/

Date Approved By: MonteP[Ph ps hief 2-oh Operational Programs Section Date Inspection Summary Inspection on July __7-11, ly86_jReports e No. 50-315f86027(DRS); 50_-_316/_86027]DRSJ1

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Areas Inspected: Special, announced inspection of actions talen on

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p(reviously-identified IE Module 92700); and items (IE Module observation 92701testin of surveillance and 92702); onsite LER followup Results: Of the three areas inspected, one violation was identified in one area (failure to adequately response timetest - Paragraph 3.b).

8608260304 860821 PDR ADOCK 05000315 G PDR

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DETAILS 1. Persons Contacted Indiana and Michigan Electric Company (I&M) and American Electric Power Services Corporation (AEPSC)

W. Smith, Jr. , Plant Manager

• Allen, Planning

• T. Beilman, Planning / Controls and Instrumentation (C&I) Superintendent

• S. DeLong, C&I

• Gallagher, Quality Control L. Gibson, Management

• P. Helms, C&I R. Heydenburg, Quality Assurance

• T. Kossack, C&I/ Planning

• T. Postlewait, Technical Superintendent, Engineering

• J. Riechling, Quality Control

• C. Ross, Computer Science Superintendent R. Russell, Quality Control J. Rutkowski, Staff Assistant J. Stietzel, Quality Control Superintendent

• B. Svensson, Assistant Plant Manager, Operations J. Anderson, AEPSC

• M. Evarts, AEPSC

• S. Farlow, AEPSC

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• R. Leonard, AEPSC K. Munson, AEPSC

• Denotes those in attendance at the exit meeting on July 11, 1986.

During the course of the inspection, the inspector also met and interviewed other members of the licensee's staf . Licensee Action On Previously-Identified Items (92701 and 92702)

(Closed) Violation (315/85028-01; 316/85028-01): Failure to perform surveillance testing at the required frequency and failure to perform adequate surveillance testin The motor driven auxillary feedwater pumps' (MDAFP) 210.2 second time delay for the 4 KV bus loss of voltage ESFAS actuation channel was not calibrated. The licensee has modified procedure 12 THP 6030 IMP.250, "4 KV Diesel Start, 4 KV ESS Bus Voltage, 34.5 KV Bus Undervoltage, and 600 Volt Bus Undervoltage Relay Calibration," to include the two-second time delay. This fulfills Technical Specification (TS) requirements 4.3.2. and 4.3.2.1.3 for both unit '

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b. The primary sensors for Overtemperature Delta T, Overpower Delta T, low-low average coolant temperature, and hydrogen recombiners' temperature channels were not calibrated as required by TS definition 1.9, " Channel Calibration." The licensee has modified existing procedures to include these sensors in their calibration program as follows:

Sensor H Procedure Incore Thermocouples Table 3.3-11 1 THP 6030 IMP.076 Item 11 2 THP 6030 IMP.276 Narrow range RTDs Table 4.3-1 IMP.076 and .276 Item 7 and 8 Wide Range RTDs Table 4.3-7 IMP.076 and .276 Item 2 and 3 Hydrogen Recombiner 4.6.4.2b1 12 THP 6030 IMP.140 Containment Humidity 4.4.4.6. THP 6030 IMP.050 Monitors IMP.076 and IMP.276 - Incore Thermocouple and Reactor Coolant System RTD Cross Calibration Test Procedure IMP.140 - Electric Hydrogen Recombiner Instrumentation Calibration IMP.050 - Containment Humidity Detector Calibration (90 Day);

the containment humidity sensors are removed and sent to EG & G for certificatio The sensor calibrations now fulfill TS definition 1.9 for both unit c. Channel functional tests (CFT) for certain RPS and ESFAS channels were not performed as required by TS Table 4.3-1 and 4.3-2, respectively. The licensee has rescheduled the CFTs to meet the frequency and modes as specified in the TS as follows:

Item TS 4.3.1.1.1, Table 4.3-1 Procedure 16 Undervoltage - RCP 12 THP 4030 STP.082 17 Underfrequency - RCP 12 THP 4030 STP.082 19 Safety Injection 2 THP 4030 STP.510 Input From ESF 2 THP 4030 STP.511 STP.082 - 4 KV Bus low Voltage Protection Surveillance Test (Monthly)

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STP.510 - Reactor Trip SSPS Logic and Reactor Trip Breaker Train

"A" Surveillance Test (Monthly)'

STP.511 - Reactor Trip SSFS Logic and Reactor Trip Breaker Train "B" Surveillance Test (Monthly)

The safety. injection input is verified monthly in the Solid State Protection System (SSPS) logic tes The SSPS test pulses overlap the ESF input circuitry wirin The manual ESF switch actuation test (refueling requirement) is verified in Procedure 2 THP 4030 STP.217A, " Diesel Generator Load Shedding and Performance Test Train A" and 2 THP 4030 STP.217B for

, Train B by actual switch manipulatio Item TS 4.3.2.1.1, Table 4.3-2 Procedure la Safety Injection Manual Initiation 2THP 4030 STP.510,

.511 2a Containment Spray Manual STP.510, .511 Initiation 3a(1) Manual Phase A Containment STP.510, .511 Isolation 3b(1)' Manual Phase B Containment STP.510, .511 Isolation 3c(1) Manual Containment STP.510, .511 Purge and Exhaust Isolation 4a Manual Steam Line STP.510, .511 Isolation 4d Steam Line Isolation 2 THP 4030 STP.119,

.120, .121, .123 Sa Turbine Trip-Feedwater Isolation 2THP 4030 STP.115,

.116, .117, .118 6a Motor Driven AFW Pumps STP.115, .116, .117,

.118 7a Turbine Driven AFW Pump STP.115, .116, .117,

.118 7b Reactor Coolant Pump Bus 2 THP 4030 STP.132, 4 Undervoltage .133, .134, .135

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STP.115 - Steam Generator Water Level Protection Set I Surveillance Test (Monthly)

STP.116 - Steam Generator Water Level Protection Set II Surveillance Test (Monthly)

STP.117 - Steam Generator Water Level Protection Set III Surveillance Test (Monthly)

STP.118 - Steam Generator Water Level Protection Set IV Surveillance Test (Monthly)

STP.119 - Steam Generator 1 & 2 Mismatch Protection Channel Set I Surveillance Test (Monthly)

STP.120 - Steam Generator 3 & 4 Mismatch Protection Channel Set I Surveillance Test (Monthly)

STP.121 - Steam Generator 1 & 3 Mismatch Protection Channel Set II Surveillance Test (Monthly)

STP.123 - Steam Generator 2 & 4 Mismatch Protection Channel Set II Surveillance Test (Monthly)

STP.132 - Reactor Coolant Pump No. 1, Undervoltage 2B Surveillance Test (Monthly)

STP.133 - Reactor Coolant Pump No. 2, Undervoltage 2C Surveillance Test (Monthly)

STP.134 - Reactor Coolant Pump No. 3, Undervoltage 2D Surveillance Test (Monthly)

STP.135 - Reactor Coolant Pump No. 4, Undervoltage 2A Surveillance Test (Monthly)

The licensee provided a current copy of the Nuclear Test Schedules (NTS). All of the above items were correctly entered in the NT In addition. all of the above items for Unit I were verified in place. The licensee was meeting the TS requirements for these items on both unit (Closed) Unresolved Item (315/85028-02; 316/85028-02): Failure to conduct a Channel Functional Test (CFT) following calibration of the Power Range Nuclear Instrumentation. Procedure 2 THP 6030 IMP.231, " Power Range Nuclear Instrumentation Calibration," was performed for all four power range channels. The licensee normally follows up a calibration with a separate CFT to demonstrate operability. Unit 2 was operating at ) 85%

thermal rated power when the licensee discovered the CFT for the power range instruments had not been performed. Approximately 21 days had passed since the calibratio p ,

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The inspector reviewed the procedure, testing method, and related drawings. It appears the calibration did meet TS definition 1.9, " Channel Calibration,".and the power range channels were operable. However, the calibration method used is not the typical method used to satisfy a channel-functional. The licensee, in this case, does have adequate CFT procedures availabl The licensee has added Step 10.4 to Procedures 2 THP 6030-IMP.231 and, 1 THP 6030 IMP.131 to verify that the appropriate CFT has been complete The inspector recommends all TS calibration procedures have a similar verification ste No violations or deviations were identifie . LER Followup (92700) (Closed) LER No. 86-006: .The response time test procedure did not

_ test through the Reactor Cooling Pump (RCP) undervoltage rela Precedure 1 THP 6030. IMP.043, " Reactor Coolant Pump Bus

. Undervoltage Relay Calibration" and 2 THP 4030 STP.100, " Reactor

! Protection and. Engineered Safeguards System Time Response," have been modified to test the undervoltage relay. The additional

. response time (0.5 seconds) has been added into past response times and the total is less than the TS Table 3.3-2 time of 1.2 seconds.

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In addition, the inspector verified that the underfrequency relay was also calibrated and its delay time was included in the overall

, response time. This was performed adequately in Procedure 12

THP 6030 IMP.041, " Reactor Coolant Pump Bus Underfrequency Relay l Calibration." The TS Table 3.3-2 response time of 1 to 0.6 seconds-

was me (Closed) LER No. 86-007: The response time test for steam generator (SG)

water level high-high signal was not tested through the turbine trip-logi Unit 1 TS addresses this response time as TS 3.3.2.1, Table The Westinghouse Standard Technical

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3.3-5, Item 8a < to 2.5 second Specification aTso lists this response time as Turbine Trip i to second Unit 2 does not have this requirement.

i The licensee tested from the SG level sensor through the master relay in the SSPS. Testing was not performed into the turbine trip

, logic and the licensee stated in the LER that no additional testing

! was require The inspector requested additional information as to

why the full logic was not teste The licensee contacted l Westinghouse.who-stated that the turbine trip logic.was part of the

! overall response time and credit was taken for it in the safety analysi As a result of this determination, on July 10, 1986, the i licensee initiated a shutdown of Unit The unit thermal power was

lowered from 35% to < 10%.

The response time from SG level high-high master relay (K508)

l through the turbine stop valve closure slave relay (K621) was I

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measured. The overall response time for each train (A and B) was

< to 2.5 seconds. Failure.to adequately test the Turbine-Reactor Trip' response time is a violation of TS 3.3.2.1-and ESF Response Time definition 1.23, Violation (315/86027-01(DRS)). (Closed) LER No. 86-008: Testing of the reactor trip from safety injection (SI) was not performed. The licensee has modified Procedures 1 THP 4030 STP.410 and 411, and 2.THP 4030 STP.510 and .511~to include testing of the. reactor shunt trip function.from SI,.TS 4.3.1.1.1, Table 4.3-1, item 1 (Closed).LER No. 85-021: Failure to perform channel functional tests as required by T Corrective action to this item is discussed in Paragraph (Closed) LER No.-85-043: Failure to perform primary sensor .

calibration The incore thermocouples, narrow and wide range RTDs, hydrogen recombiner thermocouples, and dew point hydrometer-corrective actions are discussed in Paragraph The licensee has modified existing procedures to include the following additional sensors in their calibration progra Sensor TS . Procedure Meteorological 4.3.3.4, 12 THP_6030 IMP.034

'. -Temperature Table 4.3-5 Elements Seismic Sensors 4.3.3.3.1, 1 THP 6030 IMP.035 i Table 4.3-4 '2 THP 6030 IMP.135 f IMP.034 - Meteorological Instrumentation Calibration-I IMP.035 and IMP.135 - Seismic Monitoring Instrumentation-Calibration

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Strong Motion Tri-axial Accelerograph

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The licensee has scheduled the above items correctly in the nuclear test schedules. The procedure modifications were adequate and the

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calibration techniques fulfilled IEEE 279, 1971, Section 4.9 on

< " Capability for Sensor Checks."

No other violations or deviations were identifie . Surveillance Testing

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The inspector reviewed additional test procedures and completed test

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packages.

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, Surveillance Precedure 1THP 4030 STP.100 and 2 THP 4030 STP.100,

" Reactor Protection and Engineered Safeguard System Time Response Test," were not clear on how the response time for power range high I

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neutron flux was measured. Review of Drawing OP-1-98530-5, " Power Range N42 Elementary Diagram," indicated that the licensee was initiating the test at the correct plac However, the special alarm bistable (To - used as the initiating time mark) was connected to the output of Module NM303, " Average Flux Isolation Amplifier."

The time mark (To) should be initiated near the input of NM310,

" Summing and Level Amplifier." The licensee took additional response times on Unit 1 and 2 of the NM310 and 303 modules. The response time was too fast to be measured on a highspeed Honeywell Visirecorder. -There was no inpact on past power range response time testin Modification of STP.100 to change the "To" initiating timing mark location for both units will be tracked as an Open Item (315/86027-02(DRS) 316/86027-02 (DRS)). Review of STP.100 past test packages found the Unit 1 test performed on August 26, 1985, did not have all the measuring and test equipment (MTE) logged on the data sheet. A trace was performed of the MTE records. The instrument mechanic had properly updated the "use" history records. This appears as an isolated case. The MTE used were "in-cal" and there was no impact on the test. The licensee issued Condition Report (CR) No. 1-07-86-821 and the specified immediate action was adequat Review of STP.100 past test package for Unit 2 test performed on

. March 12, 1984, found the Setra pressure transducer calibration data sheets missing. (The procedure required that the data sheets be attached to the test package). The instrument mechanic had properly logged the transducer on the data sheet. The transducer was "in-cal" and there was no impact on the test. The licensee issued CR No. 2-07-86-820 and the specified immediate action was adequat The inspector recommends the step to attach the Setra transducer data sheets to the test package be removed. Logging the transducer on the data sheet will provide the necessary MTE traceabilit Review of Procedures 12 THP 6030 IMP.073 and 2 THP 6030 IMP.273,

" Time Delay Device Calibration," fu.d both procedures were used for relay calibrations. The inspectw o commends a thorough review be completed on both proceduren 7b t ne "12" procedure and remove any Unit 2 devices; change chi ' M' ; rocedure to a Unit 1 procedure. This would prevent a po.ential scheduling conflict and ensure the correct unit relays are calibrate Review of Procedure 1 THP 4030 STP.019, " Steam Generator 1 & 2 Mismatch Protection Channel Set I Surveillance Test (Monthly),"

found administrative signoffs not in effect on similar steam generator mismatch procedures.

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The other procedures were as follows: 1 THP 4030 STP.020, " Steam Generator 3 & 4 Mismatch Protection Channel I Surveillance Test (Monthly)"; 1 THP 4030 STP.021, " Steam Generator 1 & 3 Mismatch Protection Channel II Surveillance Test (Monthly)";

1 THP 4030 STP.022, " Steam Generator 2 & 4 Mismatch Protection Channel Set II Surveillance Test (Monthly)".

, , The inspector recommends a procedure review / change policy be developed to ensure similar procedures are updated with current plant practice The potential exists for not adhering to upper tier document changes, The inspector observed portions of surveillance tests 1 THP 4030 STP.410 and 1 THP 4030 STP.020. Quality Control (QC) did not provide any coverage during the tests. The tests were performed satisfactoril The instrument mechanics were qualified to perform the test and they were knowledgeable on the procedures, operating the

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test equipment, and the system under. tes .

. The technical knowledge of personnel involved in surveillance testing is good. The licensee is continuing with a Technical Specification and surveillance test procedure review. Increased emphasis on improving surveillance test procedure review and change policies will continue

' improvement of the surveillance test progra No violations or deviations were identifie . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. An open item disclosed

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during the inspection is discussed in Paragraph . Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)

on July 11, 1986, to discuss the scope and findings of the inspectio The licensee acknowledged the statements made by the inspectors with respect to items discussed in the report. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.

l The licensee did not identify any documents / processes as proprietary.

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