IR 05000346/1986030

Insp Rept 50-346/86-30 on 861014-870227.No Violations Noted. Major Areas Inspected:Licensee Actions on Previous Insp Findings,Followup on LERs & Performance of Srtp Test Procedure Review & Witnessing.Two Open Items Documented

ML20207T320
Person / Time
Site:	Davis Besse
Issue date:	03/18/1987
From:	Vandenburgh C, Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20207T310	List: IR 05000346/1986030 ML20207T309
References
50-346-86-30, NUDOCS 8703230434
Download: ML20207T320 (15)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-346/86030(DRS)

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-Docket No. 50-346    License No. NPF-3 Licensee: Toledo Edison Company-Edison Plaza, 300 Madison Avenue Toledo, OH 43652 Facility Name: Davis-Besse 1 Inspection At: Oak Harbor, Chio Inspection Conducted: October 14, 1986 through February 27, 1987 h -

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-Inspectcrs: Chris A. VanDenburgh '

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  . $j b M Approved By: Geo,4ff Ny E. Wright; Chief  3//f/97 Test Programs Section  Date Inspection Summary Inspection on October 14, 1986 through February 27, 1987, (Report No. 50-346/86030(DRS)) .

Areas Inspected: Special announced inspection by regional, headquarters and contractor inspectors to review licensee action on previous inspection findings; follow up on Licensee Event Reports; perform SRTP test procedure review and , witnessing; perform SRTP test results review and evaluate the effectiveness of training and qualification Results: Of the five areas inspected, two open items are-documented in the

body of the report which will require action by the licensee to resolve.

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I ' 8703230434 870318 '

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PDR ADOCK 05000346 G PDR i

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DETAILS Persons Contacted Toledo Edison

 'L. Storz, Plant Manager S. Smith, Assistant Plant Manager, Maintenance
 *E. Salowitz, General Superintendent, Outage and Program Management
 *L. Ramsett,-Quality Assurance Director R. Peters, Nuclear Licensing Manager J. Wood, Nuclear Plant Systems Engineering Director

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 *J. Sturdavant, Licensing Specialist i

R. Flood, Technical Support Manager R. Cook, Acting Compliance Supervisor S. Jain, Nuclear Engineer P. Hildebrandt, Nuclear Engineering Group Director S. Jain, Nuclear Engineering Manager

 *S. Piccolo, Assistant Restart Manager P. Anthony, Technical Support Engineer W. Siferd, Technical Support Engineer D. Harris, Quality Assurance C. Cousino, Metrology Laboratory Supervisor
 *0. Mavro, Consultant NRC
 *C. VanDenburgh, RIII Reactor Inspector P. Byron, Senior Resident Inspector
 * Kosloff, Resident Inspector R. Smith, Inspection and Enforcement J. Brown, Inspection and Enforcement L. Valenti, EG&G
 * Denotes those personnel attending the February 27, 1987 exit meetin The inspectors also interviewed other licensee employees, including members of the technical, operations, engineering and maintenance staf . Licensee Action on Previous Inspection Findings (0 pen) Violation (346/85039-04): This item was identified in LER 86-004 and discussed in Inspection Report No. 50-346/85039 as Violation 85039-04. The violation identified a failure to demon-strate the operability of the High Pressure Injection (HPI) System due to an inadequate Technical Specification (TS) Surveillance Tes An additional example of this violation was identified in LER 86-023 and discussed in Inspection Report No. 50-346/86015, Paragraph This example identified a failure to demonstrate the operability of the Decay Heat Removal / Low Pressure Injection (DHR/LPI) System due to an inadequate Technical Specification (TS) Surveillance Tes ,-
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The remaining corrective action for this violation was to revise Surveillance Test ST 5031.07, " Integrated SFAS Test," following the completion of Test Procedure (TP) 850.19, " Integrated SFAS."

The inspector has verified that this revision has been complete As a result of these violations and-four additional examples, ( LERs 85-018, 85-021, 85-022 and 87-003), the licensee has implemented a program to conduct a review of Technical Specification required

 . testing to identify acceptance criteria which may have been omitted from periodic test procedures. Phase I of the Technical Specification Verification Program (TSVP) is described in Nuclear Licensing Procedure NSL/LIC-012, and TSVP Instructions TSVP-01 and TSVP-02. Phase I-verified prior to restart that all Technical Specification Surveillance Requirements were addressed by a Surveillance Test or implementing i procedure.~ Phase II will be developed and accomplished following l restart and is intended to cover in detail a review of all remaining Technical Specification sections, a review of all other pertinent licensing documents (e.g., USAR, LCTS, SER, etc.), a detailed pro-grammatic review of all Technical Specification implementing procedures (including Surveillance Test and implementing procedures) and a field verification (plant walkdown) of Surveillance Test and implementing procedures. The Phase II review will verify that all Technical Specification requirements are implemented by a Davis-Besse procedure, program or other document and that the Technical Specification and implementing documents are individually vali Phase I of the TSVP was completed prior to restart by the development, review and resolution of 332 review packages. The implementation and completion of Phase II of the TSVP will be followed as a new Open Item (346/86030-01). (Closed) Open Item (346/85039-09): This item concerned a commitment to revise the Updated Safety Analysis Report (USAR) description for the turbine trip and turbine loss of load transients and the System Review Report (SRR) list of functions for the Anticipatory Reactor Trip System (ARTS) trip. The USAR revision has been prepared for a future submittal. The revision adds a new Section 15.2.7.3 which indicates that the function of reactor runback and turbine bypass is the anticipated response to a loss of external electrical loa The Integrated Control System (ICS) SRR has been revised to indicate.that the functions of reactor runback and turbine bypass are not functions i  "Important to Safe Plant Operation" and as such are not required to i

be tested as part of the SRTP. The inspector has verified that this is consistent with the requirements of SRTP-002, " Guidelines for the Identification of System Functions." This item is considered closed.

f (0 pen) Unresolved Item (346/86009-02): This item concerned the lack ! of venting of High Pressure Injection System (HPI) high point vent LER 86-012 reported that due to an inadequate review of the Surveil-lance Test ST 5051.11, " Venting Emergency Core Cooling System (ECCS) Surveillance Test," a change to Technical Specification (TS) 4.5.2b, as implemented by License Amendment 25, to require that the HPI high point vents be vented every 18 months or prior to operation after ECCS piping had been drained was not incorporated. This resulted in

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s the HPI high point vents not being vented for a period in excess of-18 months. Venting of the piping is required to ensure that a water-hammer is not generated when coolant discharges into an empty lin The LER indicated that there was no safety significance to the' lac of. venting of.the HPI high point vents based on a Bechtel Corporation evaluation of the mechanical effects on the piping as referenced in Final Safety Analysis Report (FSAR) Questions and Answers Page .5.5.1- This evaluation had been requested by the inspector.for review; however, the licensee indicated that it could not be located. The licensee is presently in the process of having Bechtel Corporation generate a new analysis to substantiate the statement in the LER. . In support'of this activity, the licensee indicated that the water hammer analysis for the affected sections of piping is not required as a

" design basis". calculation and need not be considered-in the Class 1
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fatigue analysis or to generate support modifications to accommodate water hammer . loads as a permanent design load. Rather, the licensee indicated in a memo (NED-86-10013) dated November 13, 1986, that the objective of the analysis is to show that if a water. hammer occurred in this area of the system, the resultant piping stresses would be within the " interim or operability limits" and the' system would still be operable. The inspector cannot evaluate the acceptability of these assumptions. . This item will remain open pending the receipt an review of this analysis. The second portion of this open item which _ required that the LER be revised to address the safety significance of the delay in HPI injection times due to the lack of venting of the HPI piping is closed based on a review of Revision 1 of LER 86-01 (Closed) Violation (346/86009-03): This violation s ,cerned the failure to demonstrate'the operability of the Auxiliary Feedwater Pump Turbine Steam Generator Level Control System due to an inade-quate surveillance test procedure and the lack of appropriate test l circuitry. The licensee responded to this violation in a letter from J. Williams to J. G. Keppler dated August 20, 1986. The inspector verified that the test circuitry has been installed and satisfactorily tested and that the surveillance test procedures have been revised to periodically test the the test circuitry. This violation is considered close (Closed) Unresolved Item (346/86009-05): This item concerned a licensee commitment to develop and implement a chronological log for the performance of Surveillance Tests (STs) performed as a part of the SRTP. The inspector has continued to review the adequacy of the chronological logs as part of the ST results review and has no further concerns in this area. This item is considered close f. (Closed) Open Item (346/86015-06): This item concerned a sticky frequency meter on Emergency Diesel Generator (EDG) 1-2 which was first identified in October 1985 and which resulted in an unsatis-factory first attempt to perform Surveillance Test (ST) 5081.0 _ _ _ _ _ _ - _ _ _ _ _ .

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i The frequency meter has been repaired by Maintenance Work Order (MWO) 1-86-2614-00. This item is considered close [ 6., (Closed) Unresolved Item (346/86022-01):, This item concerned the failure of the Reactor Coolant Pump (RCP) 2-2 lawar guide bearing during the performance of TP 851.42, "RCP' Flow hsting." As a result cf incomplete maintenance activities ano dte to inadequate , operational and testing control.of the tkst presedure; the RCP e bearing was allowed to overheat W d fail during f;he initial uncoupled motor run-in performed on October 1, 1986. The licenset. investigated t the circumstances of this event and documented corrective actions in f

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-Potential Condition Adverse to Quality (PCAQ) 86-0454. Following    4 completion of the corrective actions, RCP 2-2 was retested on Nov m.ber 17 and 19, 1986. Although unusual noises and bibrations wdre observed    -

by the test personnel following testing and during the plant heat up,  ? in Mode 4, further licensee investigation deter;nined that RCP y-2 is j , s

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fully operationa ' An additional. problem was noted with testing ccatrol during the performance of TP 851.11, MSIV - SFRCS Response Time Test," on December 3,'1986, and the parformance of TP 851.27, " Power Operated Relief Valve (PORV) 700 psig and 2155 psig Stroke Testing," on December 5, 1986. With respect to the performance of TP 851.11, _ the licensee determined that the Test Leader preparation w'a; f ude- . quate to support the timely; performance W the. test procedure, in that the required test equipment was not available and the Test Leader was not sufficiently familiar with the requirements'of the test procedure. Testing and operational management overview identified that control of testing was inadequate and-Tmplemented adequate immediate corrective actions to restore' test. control. With respect to the performance Mf TP 851.27, the licensee determ*n'ad that the' performance of the Test Leader was inadequatty in that the stroke testing of the PORV was performed seven instea'c of eight tittss as reg,uired by the test procedure. The foot ca m of cne error has been determined to be personnel error an1 adtqu ne corrective actions, have been taken to prevent recurrence. This item' is discussed furthqr in Payagraph 5.e of this repor (Closed) Open Item (346/86022-02): This item concerned the results , review of TP 851.00, in which the inspector noted that the test - methodology for measurement of ventilation flow in a duct was changed and later accepted following an engineering evaluation. . Teit Deficiency 851.00-2, was initiated when the air flow tra.nsverse of

. Step 7.3.9 could not be performed as specified in Attachment " Attachment I required eight test ports (64 test. points); houver only seven test ports (56 test points) were prpvided. An engineeM ng evaluationwasperformedtoresolvetbeympactofusing56' test     ,

points vice the originally required 64 test points. This evaluation concluded that the difference in the number of test points did not effect the acceptability of the test date and therefore, the accep- s tance criteria for the ventilation flow'az measured was conservative and acceptable. The inspector's review mi this' evaluation detsrmined that it was incorrect and was not performed in accordance with accepted statistical analysis metNd Subsequent review by the

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licensee determined.that the analysis was not performed nor approved

~j '    in accordance with Nuclear Engineering Procedure NEP-080, " Calculations,"-
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and was therefore withdraw . . < . . _ Further review-by the inspector. identified an additional concern, in L that the use of. a -pitot tube transverse-alone for the measurement of . ventilathn flow in this test application was not in accordance with

   . industry 3 e.ardards. American Society for Test and Materials (ASTM) -

' 9 . .Procedur40;3154-72,whichwasidentifiedastheapplicablestandard -

   .in.the engineering evaluation discussed above,. indicates that when sampling sites are less than two diameters downstream of any flow Q '

disturbances, reasonable accuracies with pitot tube measurements can ' not be expected and another method for flow measurement should be

used._ As verified by the inspector, the sampling sites used were less that one _dtameter downstream 'of a significant flow disturbance . '

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   ~(i.e. two adjacent 90 degree bends). As additional guidance, Regula-

tory Guide 1.140, " Design, . Testing, and Maintenance Criteria for Normal Ventilation Exhaust System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants," Revision 1 of October h ' 1979, references Industrial Ventilation, 18th Edition, by the American Co'nference of Governmental Industrial Hygienists, which in Section 9,

   " Testing of ventilation Systems," indicates that test results must be    :

L, considered subject to some doubt and checked against a second location

Y for. agreement within 10 percent if the measurements are made closer that 7.5 duct diameters to.any major air disturbance. The inspector therefore concludes that the use of the pitot tube measurement ,

[ technique _alone in this application is not considered acceptable.

. The inspector additionally determined that during the performance of

p ventilation flow measurements in a similar application on Auxiliary t

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Building Low: Voltage Switchgear Fan C71.1 in Test Procedure (TP) 7. y

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b 851.04, a rotating vane anemometer was used at the discharge duct as ! i ,, opposed to a pitot tube transverse method of measurement of in-duct +

   ' flow velocities. This measurement method meets the requirements of both.riference The licensee -has developed a letter to file (NE0-86-00116) dated December 5, 1986, in accordance with Restart Administrative Instruc-tion RAI-6, which withdraws the incorrect engineering evaluation and    ;
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documents the circumstances concerning the development and approval

}# of the evaluation. The letter to file additionally documents that,

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although the pitot tube transverse methodology is not recommended, it , t was selected as the test method due to duct accessibility for future -

 ,   repetitive performance testing. Additionally, data taken subsequent
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is acceptable. The inspector has no further concern a

 , i (Closed) Unresolved Item (346/86022-03): This item concerned the
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temperature switches with respect to charcoal filters in Request For i , [[ Engineering Assistance (REA) 86-I-0090-00 in TP 851.14, " Emergency l_ T Vent u t{cn System Cross-Tie Ventilation Test." Although engineering ,. S_ justificttions were considered to be good practice, the inspector has j . l1

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original' question. Thisfitem is considered close , (Closed);0 pen Item (346/86022-04): This item concerned the results

  ;g evaluation of:TP 851.21, in that steps 6.3.1 and 6.3.2 were not signed E

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  .asjcompleted. A note in the test procedure refers to TD 851.21- / Further review has identified that the test steps were not signed due to' typographical errors in;the' steps, and that-the completion of the
  .stepsiwere satisfactorily, documented in the deficiency. This item is considered close '

Nodiolations'ordeviationswereidentified. There was one previous unresolved item and one previous violation discussed in this section of the report which will require further licensee action to resolv . Licensee Event Reports i

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Through direct observations, discussions with licensee personnel, and , review of records, the following event reports were reviewed to determine:

.  .that reportability requirements were fulfilled, immediate corrective  '

, action was accomplished, and corrective action to prevent recurrence had

*  been accomplished;in accordance with Technical Specifications.

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  - (Closed) LER 86-012, Lack of Venting' of High Pressure Injection (HPI)

High Point Vents. 'As corrective actions for this LER the-licensee

  ; issued Revistorr 1 to the LER to address the safety significance of the delay in injection times due to the lack of venting of the HPI discharge piping and modified Surveillance Test ST 5051.11, " Venting of ECCS Piping," to include the venting of HPI Valves HP-75, HP-77 and HP-81. UThe remaining action item regarding the Bechtel evaluation of the potential' water hammer effects on the discharge piping is being

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  -followed as an' unresolved item and is discussed in Paragraph 2.c of-the report. This LER is' considered close M
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? (Closed) LER 86-014, -Inadequate Auxiliary Feedwater Pump Turbine W     _
  .(AFPT) >Steafn Generator Level Controller. As corrective actions for i    this LER the licensee implemented FCR 86-108 to add test. circuitry

'. o 'and completed TP 850.79, "AFPT S/G' Level Control," to test the new

.. circuitry. 1The inspector has verified that the testing was completed-
<?   satisfactorily ar.d that the surveillance test has been. revised to is Ih    require periodic testing of the new circuitry. This LER is considered close ', (Closed) LER 86-023, Lack of Stroke Time Testing of Decay Heat Pump Suction Valves. The remaining corrective actions for this LER
.,   included the completion of Test Procedure (TP) 850.19, " Integrated S  SFAS," and a revision to Surveillance Test (ST) 5031.07, " Integrated E,N  -

SFAS." The inspector has v'erified that TP 850.19 has been completed 19 ff

'[,  and ST 5031.07 has been revised. As an additional corrective action

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undertaken in response to five previous similar occurrences in which '

  .the Technical Specification Surveillance Requirements were not being hf    correctly implemented by the Surveillance Tests, the licensee has s'

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which is discussed in Paragraph 2.a offthis report. This .LER is considered close (Closed) LER 86-026, Design'and Testing Deficiencies for the-Atmospheric Vent. Valves. As a result of a design review the licensee determined that the tubing between the air volume tank and the actuator was too restrictive. .The inspector has verified that the

 ? tubing has been replaced and satisfactorily tested'and that the periodic testing'has been revised to adequately test the valv s  _
 ~This LER is considered close L .(Closed) LER 86-029, Design and Installation of Containment Air Cooler Valves. As a result of the System Review-and Test Program, the b   licensee identified that the Containment Air Cooler (CAC) outlet
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 -valves were, closed by air pressure from a non-seismically qualified, t   non-safety grade system and therefore credit could not be taken for-E

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 . their isolation capabilities. -The inspector has verified that the air supply. system has been modified to provide a seismically qualified

's source of air to the CAC outlet valves. This LER is considered close No violations or deviations were-identified. There were no open or iunresolved items identified 4.a this section of the repor ~

- SRTP Test Procedure Review and Witnessing The inspectors reviewed and/or observed the following Technical Specification required surveillance testing, periodic t'esting and one time performance

, testing which were utilized to verify the functional. operability of the L systems.. This review verified that the' test procedures adequately demon-strated the conditions to the maximum extent practicable; were reviewed and approved;oy the appropriate management personnel; and contained appropriate

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acceptance criteri In addition, the observation verified that the-testing was performed in accordance with approved procedures; limiting conditions-for operations were met; and that deficiencies encountered during the performance of the procedure were adequately documented and resolved prior to proceedin ~

  -TP 850.19, " Integrated Safety Features Actuation Testing" TP 850.52, " Auxiliary Feedwater Monthly Test" TP-850.53, " Auxiliary Feedwater Instrumentation Calibration" TP 850.71, " Steam and Feedwater Rupture Control System Integrated Test - Cold" TP 850.75, " Control Room Emergency Ventilation System HVAC Performance Test" TP 850.84, " Makeup Valves Air System Integrity Test" TP 850.85, " Reactor Coolant System Isolation Check Valve Leak Test"
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TP 850.99, " Auxiliary Feedwater/ Main Steam Vibration Test" TP 851.06, " Auxiliary Feedwater Pump 1-2 Instrument Calibration" TP 851.10, " Atmospheric Vent Valve Operation and Response Time Test"

 ,TP 851.11, "MSIV-SFRCS Time Response Testing"
,;  TP 851.52, " Main Feed Pump Capacity Test" TP 851.53, " Motor-Driven Feedwater Pump Minimum Recirculation Capacity Test"

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TP 851.54, " Motor-Driven Feedwater Pump Circuitry Monitor Test" PT 5136.02, " Main Feed Pump Turbine Lube 011 System" PT 5136.03, " Main Feed Pump Overspeed Test" ST 5011.06, " Boron Injection Flowpath Refueling Valve Test" ST 5030.05, " Reactor Coolant System Input to Reactor Protection System Calibration" ST 5031.03, " Containment Pressure to SFAS Channel Calibration" ST 5031.04, " Containment Radiation Monitor Input to the Safety Features Actuation System Calibration" ST 5064.01 " Containment Isolation Valve Post-Maintenance Test" ST 5081.04, " Diesel Air Start System Relief Valve Test"

 .a. With respect to the performance of TP 851.10, the inspector noted that the original performance of the test procedure was unsatisfactory because the ball' check valve on the air supply to the air volume tank was discovered to be installed backward. The valve was repaired and the test completed satisfactorily. The valve was installed incorrectly during maintenance which was performed to corrset leakage identified during the testing of the Air Volume Valves (AVVs) in TP 851.18, "AVV Air Volume Tank Pressure Drop Test." The root cause of the inadequate maintenance has been determined to be personnel error. There are no further concerns with this tes b. With respect to the performance of TP 851.11, the inspector noted that following the test performance in Mode 4, the Independent Process Review Committee (IPRC) identified during the results evaluation that TP 851.11 did not require the Main Steam Isolation Valve's (MSIV)

stroke time to be adjusted to a value between 4.5 and 4.8 seconds as required by the Test Outline, MSP-TPO-007. The values obtained during testing were between 3.44 and 4.18 seconds. Further evaluation and consultation with the valve manufacturer, Rockwell International, determined that the stroke times obtained were acceptable. Based on this engineering evaluation, the test results were approved and entry into Mode 3 was allowed. After entry into Mode 3, further consulta-tion with the manufacturer identified that the performance of the valves with the as-found stroke times was not recommended. The licensee subsequently suspended heat up and adjusted the stroke times to the recommended values. During the review of the test data, the IPRC identified that the stroke times for MSIV MS-101 did not correlate with the speed adjustment setting Further investigation identified that the stroke times were in excess of that allowed by Technical Specification 3.7.1.5, in that stroke times less than five seconds could not be achieved. Following unsuccessful attempts to repair the valve in Mode 3, the plant was cooled down to Mode 4 to allow for further repair Following repairs and troubleshooting, the MSIVs were satisfactorily demonstrated to close in less than five seconds in Mode 4, thereby satisfying the Technical Specification Surveillance Requiremen However, additional testing conducted in Mode 3, demonstrated that i

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 .the closure time'for MS 101 was greater than five seconds. -The
 ' licensee determined thatLthe MSIV's were operable based on a review'
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 .of:the~ Technical ~ Specification Basis. -This review and its'
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conclusions were documented ~ in a letter from J. Williams, Jr.' to J. G. Keppler dated December ~22, 1986-(Serial No. 1-698).. The conclusions of this-analysis were discussed between senior RIII/DRS and NRR management on. December 22, 1986,.at which-time NRR confirmed the licensee's. conclusion that the MSIV's were operable. The results of the' Mode 3 testing has been reviewed by the inspector and documented in-Section 5 of this report.. There are no further-

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l Econcerns with this tes A similar instance in which a test procedure did not incorporate the-appropriate requirements as approved by-the IPRC and as stated-in the test outline was previously identified by the IPRC and is discussed in Paragraph 5.c of this report. The IPRC review of test summaries is specifically intended to ensure that the test results meet the requirements of the test outlines. .As discussed in Paragraph 5.c, the licensee has concluded that-these instances are not indicative of a programmatic breakdown in the quality of the test procedure This conclusion appears to be appropriate. The inspector has no L further concerns in this are No violations.or deviations were identified. There were no open or unresolved. items-identified in this section of the repor ' ' SRTP Test Results Review The inspectors reviewed the results of the following Technical Specification required surveillance testing, periodic testing and one time performance testing which were utilized to verify the functional operability of the systems. This review verified that the licensee is performing an adequate

 , evaluation of test results; that all test data is either within previously established acceptance criteria or that deviations are properly documented and evaluated; and that test results are revieweg, evaluated and approved by the appropriate management personne TP 850.03, " Motor-Driven Feedwater Pump Acceptance Test" TP 850.05, " Component Cooling Water Flow Verification for Safety Features Actuation Level 3" TP 850.08, " Service Air Compressor Sequencer Checkout" TP 850.12 " Integrated Electrical Testing" TP 850.18, " Integrated SFRCS/AFW" TP 850.19, " Integrated SFAS" TP 850.20, "ICS/MFW Integrated Testing" TP 850.23, " Containment Spray 57% Valve" TP 850.25, " Decay Heat System Flow Test" TP 850.28, " Containment Air Cooling Fan Overload Test" TP 850.30, "AFPT Main Steam Test" TP 850.31, " Containment Air Cooler Damper Test"
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. TP 850.34, " Containment Air Cooler Performance Test" TP 850.39, "CRD Stator Current Check" TP 850.43, " Auxiliary Feedwater Logic Verification" TP 850.45, "AFPT Admission Valve Testing on Auxiliary Steam" TP 850.48, "AFPT Admission Valve Cold Testing" TP 850.49, " Auxiliary Feedwater System Refueling Test" TP 850.50, " Auxiliary Feedwater Pump Turbine Overspeed Test" TP 850.52, " Auxiliary Feedwater Pump Monthly Test" TP 850.54, " Auxiliary Feedwater Pump Channel Functional Test" TP 850.55, " Containment Normal HVAC Performance Test" TP 850.59, " Component Cooling Pump Room Ventilation Test" TP 850.60, " Main Feedwater Pump Turbine Drain System" TP 850.65, " Auxiliary Feedwater Steam Line Break Alarm" TP 850.66, " Steam and Feedwater Rupture Control System Logic Verification - Cold" TP 850.68, " Steam and Feedwater Rupture Control System Cabinet Cooling Test" TP 850.71, " Steam and Feedwater Rupture Control System Integrated Test - Cold" TP 850.75, " Control Room EVS HVAC Performance Test" TP 850.76, "CAS HVAC Testing" TP 850.79, " Auxiliary Feedwater Pump turbine Steam generator Level Control" TP 850.80, " Auxiliary Feedwater Pressure and Valve Test /HAFA" TP 850.84, " Makeup Valves Air system Integrity Test and MU-33" TP 850.85, "RCS Isolation Check Valve Leak Test" TP 850.86, " Nitrogen System / Reactor Coolant System Valve Leakage Test" TP 850.92, " Service Water Ventilation Operational Test" TP 850.93, " Fire Protection / Radiation Monitor Alarm test" TP 850.96, " Auxiliary Feedwater Pump Room Ventilation Test" TP 850.99, "AFW-MS Suppression Line Vibration Test" TP 851.00, " Low Voltage Switchgear Room Ventilation Test" TP 851.04, " Low Voltage Switchgear Fan C71-1 Acceptance Test" TP 851.06, " Auxiliary Feedwater Pump 1-2 Instrument Calibration" TP 851.07, " Motor-Driven Feedwater Pump Monthly" TP 851.08, " Motor-Driven Feedwater Pump Quarterly" TP 851.10, " Atmospheric Vent Valve Operation and Response Test" TP 851.11, "MSIV-SFRCS Time Response Testing" TP 851.12, " Essential Heater Bank Capacity" TP 851.13, " Reactor Coolant System Hot Leg Level Functional Test" TP 851.14, " Containment Emergency Ventilation System Cross-Tie Damper Test" TP 851.15, " Decay Heat System Isolation Test" TP 851.18, " Atmospheric Vent Valve Volume Tank Pressure Drop Test" TP 851.20, "DH-1A(B) Switch Verification" TP 851.21, "DH-9A(B) Open Operational Check" TP 851.22, " Backup Service Water Pump Test" TP 851.23, " Cross-Tie of Motor Control Centers E118 and Fila" TP 851.24, "RCS Vent Path Operability"

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 -TP'8'1.25, 5 "MU-33 Valve-Opening Delta-P"
 - TP 851.26, " Makeup Flow Test at High Pressure"  .
 'TP 851.27, " Power Operated-Relief Valve.(PORV) 700 psig and 2155
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psig Stroke Testing" ; ~

 .TP 851.29, " Component: Cooling Water Check Valve Test /HAFA "
 - TP 851.30, " Reverse Flow Test (FW-988 and FW-491) -:HAFA"
 :TP 851.31, " Reverse Flow Test Main Feedwater-Check Valve /HAFA" LTP. 851.32,,"Feedwater. Control Valve Response on Loss' of. InstrumentL Air":
 .TP 851.36,?'? Containment-Spray Pump Discharge Valve Throttle ~

L Settings"

 :TP 851.37, "High Pressure System-Isolation Test"
 :TP 851.38, "13.8 KV Relay Protection" TP 851.39, "4160 V Load Breaker _ Relay Test" TP 851.40, "4160 V Buss C2/D2 Protective' Relay Functional Test"
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TP 851.41, " Makeup Tank - Makeup Suction Valve Control Scheme"' TP 851.42, "RCP Flow Testing" TP 851.43, "SFAS and EDG Disconnect Switch" ~

 - TP 851.45, "RC Letdown Line Test" TP 851.46, " Operational Test of PASS" TP 851.47, " Component Cooling Water / Reactor Coolant System High Pressure Interlock"
 'TP 851.48, " Replacement Station Battery Acceptance Test" TP 851.49,' "MOVATs Differential ~ Pressure Test AF-608"'

TP 851.50, " Auxiliary Feedwater Valve AF-599 Differential Pressure-Test" TP 851.51, " Auxiliary Feedwater Valves AF-3869 and AF-3870 -DP Test"- TP 851.53,J" Motor. Driven Feedwater Pump Minimum Recirculation-Capacity Test"- PT 5126.02, " Emergency Diesel Generator Fuel Oil Transfer System" PT 5136.02, " Main Feedwater Pump Turbine Lube Oil System" ST 5010.03, "Po'st Refueling Physics Test" ST 5013.02, " Control Rod Assembly Insertion Time Test" ST 5013.04, " Control Rod Exercise Monthly Test" ST- 5016.16,~ " Fire Protection System Flush" ST 5030.02, " Reactor Protection System Functional Test" ST 5030.04, "RCS Pressure to RPS Calibration" ST 5030.05, "RCS Pressure to RPS Calibration" ST 5030.19, " ARTS Turbine Generator Input Logic Test" ST 5030.22, " ARTS Control Rod Drive Breaker Functional Test" ST 5031.02, "RCS Pressure to SFAS Calibration" ST 5031.03, " Containment Pressure to SFAS Channel Calibration" ST 5031.04, " Containment Radiation Monitor Input to SFAS Calibration" ST 5031.09, " Steam and Feedwater Rupture Control System Refueling Test" ST 5031.10, " Steam and Feedwater Rupture Control System Instrument Inpw. Response Test" ST 5031.12, " Steam and Feedwater Rupture Control System Overall Response Time Calibration"

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ST 5031.15, " Steam and Feedwater Rupture Control System Pressure

 . Inputs" ~

o -ST'5031.26,." Response Time Test of TTA/TTG Relays"

, ST 5032.02, " Radiation Monitoring System Channel Calibration"'

ST 5039.00, ." Pressurizer Power Operation and Safety Valve Monthly . System Functional Check" ,

'ST 5043.01, " Primary and_ Secondary Radiochemistry" ST 5043.02, " Primary Chemistry" ST 5051.10, " Decay Heat / Low Pressure Injection Pump and Check
 ' Valve Test" ST 5062.02, " Containment Spray System Refueling Test" ST 5064.01,'" Containment Isolation Valve Post-Maintenance Test"~

ST 5071.05, " Auxiliary Feedwater 18 Month Calibration" ST 5071.06, " Auxiliary feedwater Contro1otron Flowmeter Calibration" ST.5074.01, " Component-Cooling Water Monthly Test" ST' 5075.01, " Service Water System Monthly Test" ST 5075.02, " Service Water System Refueling Test" ST 5091.01, " Source Range Functional Test" With respect to the test results review of TP 850.03, the inspector noted that the three-way valve downstream of the Motor-Driven Feedwater Pump (MDFP) was damaged during testing and may have been a source of noted high vibrations. Following the completion of testing, the valve was removed and replaced by an orifice and a locked open isolation valve. Due to the change in the recirculation flow configuration, a-new test procedure TP 851.53, "MDFP Minimum Recirculation Capacity Test," was developed to demonstrate acceptable operation. The results of this testing were reviewed as a part of the results evaluation of the test program. There are no further concerns with this tes With respect to the test results review of TP 850.52, the inspector noted that the pump performance of Auxiliary Feedwater (AFW) Pump 1-1 is marginally acceptable in that the developed head at the minimum allowed turbine speed allows no margin for future pump degradatio The licensee identified that prior to the next performance of the quarterly surveillance test for AFW Pump 1-1 operability, either an increase of the turbine high speed limiter setpoint or a Technical Specification change will be implemented to require less AFW flo These corrective actions will be followed as an open item pending completion (346/86030-02). With respect to the test results review of TP 850.55, the inspector noted that a Potential Condition Adverse to Quality (PCAQ) 86-0490 was initiated on October 10, 1986. The test results were approved by the Joint Test Group (JTG) on September 24, 1986, and a subsequent review by the Independent Process Review Committee (IPRC) determined that a potential problem may have existed in that the acceptance criteria specified for the test were not those required by the IPRC in the development of the test outlin Further review confirmed that one acceptance criterion was incorrectly stated and consequently, the test results evaluation was not valid. As corrective action, the

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licensee withdrew approval of the test results, revised the acceptance criteria and subsequently reviewed and approved the test results based on the new correct acceptance criterion. Additionally, the licensee conducted an audit to determine if this discrepancy was an isolated occurrence or indicative of a generic problem with the development of the test procedures. Based on a review of sixty-four test procedures, the licensee has concluded that the condition was a single occurrenc The inspector has reviewed the results of this audit and the completed test results for TP 850.55 and confirms the licensee's conclusion There are no further concerns with this tes With respect to the test results review of TP 850.96, the inspector determined that an incorrect correction factor was used during the data reduction. During the performance of March 25, 1986, Vane Anemometer, I&C 4.02.004, Serial No. 567108, was used to measure ventilation flow. The correction factor used in the data reduction to compensate for the calibration deviation was derived from the calibration of the Davis Instrument Standard, Serial No. 526208, and not from the calibration of the Vane Anemometer, Serial No. 56710 The use of the wrong correction factor resulted in a difference in total ventilation flow of 0.003% and does not effect the acceptability of the test results. This discrepancy has been documented in a letter to file in accordance with Restart Administration Instruction RAI- There are no further concerns with this tes With respect to the test results review of TP 851.27, the inspector noted that the PORV was stroke tested a total of seven instead of eight times as required by the test procedure. Section 3.2.1.6 of

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the Safety Evaluation Report (NUREG 1177) also indicates in that the licensee will stroke test the valve eight times at a nominal pressure of 700 psig. The licensee identified and subsequently approved this deviation based on the intent of the stroke testing to demonstrate operabilit The choice of eight strokes was a compromise between demonstration of long term operability and degradation of the valve seating surfaces. The inspector has verified in a telephone conver-sation with the Licensing Project Manager in the Office of Nuclear Reactor Regulation (NRR) that this deviation is an acceptable alternative based on this analysis. There are no further concerns with this tes No violations or deviations were identifie There was one open item identified in this section of the report which will require further action by the licensee to resolv . Training and Qualification Effectiveness Throughout the course of the inspection, there were no deficiencies or direct observations with respect to the effectiveness of personnel training and qualification. No violations or deviations were identifie . _ _ _ _ _ _ _ _ _ _ _ _ -

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. Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part of NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 2.a and . Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)

throughout the inspection and at the conclusion of the inspection and summarized the scope and findings of the inspection activities. The licensee acknowledged the findings. After discussions with the licensee, the inspectors have determined there is no proprietary data contained in this inspection repor i

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