IR 05000354/1985061

Resident Safety Insp Rept 50-354/85-61 on 851201-860112. Violations Noted:Test Sequence for Preoperational Test Procedure PTB-AB-1 Changed & Retesting Performed W/O Documentation & Approval

ML20151Z337
Person / Time
Site:	Hope Creek
Issue date:	01/31/1986
From:	Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151Z286	List: IR 05000354/1985061 ML20151Z283 ML20151Z317
References
TASK-1.A.1.2, TASK-1.C.3, TASK-1.C.5, TASK-TM 50-354-85-61, IEB-79-24, IEB-85-002, IEB-85-2, IEC-78-16, IEC-81-04, IEC-81-4, NUDOCS 8602140140
Download: ML20151Z337 (13)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

I Report No. 50-354/85-61

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Docket 50-354 ,

License CPPR-120 Licensee: Public Service Electric and Gas Company Facility: Hope Creek Generating Station i Inspection at: Hancocks Bridge, New Jersey Conducted: December 1, 1985 - January 12, 1986 Inspectors: R. W. Borchardt, Senior Resident Inspector . ash eactor Engineer ,

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Approved: _&m__ dp __

/ / #6 Strosnider, Thief, Projects Section IB ' Date Inspection Summary:

Areas Inspected: Routine onsite resident inspection of the following areas:

followup on outstanding inspection items, preoperational phase activities, construction activities, site management changes and inspection program status. This inspection involved 265 hours0.00307 days <br />0.0736 hours <br />4.381614e-4 weeks <br />1.008325e-4 months <br /> by two resident inspector Results: This report documents two violations identified by the NRC inspectors. The bypassing of a quality control mandatory witness point (paragraph 3.3) during the performance of a preoperational test is of particular concern to the NRC. It appears that not all test engineers fully understand the guidance provided in the startup administrative procedures concerning retests and the performance of steps and sections of procedures out of order. Considering the high level of activity in the preoperational test area this violation deserves prompt attentio ,

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Details 1. Persons Contacted Within this report period, interviews and discussions were conducted with members of the licensee managemert and staff and various contractor per-sonnel as necessary to support inspection activit . Followup on Outstanding Inspection Items 2.1 Violations (Closed) Violation (85-27-02), Failure to follow Startup Administra-tive Procedure (SAP) 24. The corrective actions implemented in re-sponse to the violation were reviewed in Inspection Report 85-2 The inspector had no further questions on the corrective action This item is administratively close (Closed) Violation (85-27-04), Failure to follow SAP 24. The viola-tion identified three examples of failure to follow this procedur These examples include 1) failure to identify an unreviewed test package as a test exception 2) changing test acceptance criteria via On-The-Spot-Change (OTS) and 3) failure to properly implement an OTS. The inspector reviewed corrective actions taken by the applican A revision to SAP-24 clarifies the use of the change notice and 0T A list of all test package reviews (TPRs) which have not received Startup Manager / Quality Assurance approval will be attached to the test during results review and is available for examination by the test engineer. The need for adherence to procedures and careful examination of test changes has been stressed during training ses-sions, and in correspondence, with both test personnel and QA/QC inspectors. The PORC Chairman emphasized the need for an intensive technical and administrative review of each test procedure by PORC members. The inspector will review implementation / effectiveness of the above action in future inspection This item is close .2 Unresolved __ Items (Closed) Unresolved Item (85-06-01), Olesel Generator Testing Re-quirements. The inspector reviewed Preoperational Test Procedure PTP-BB-3 (Part A), Revision 0, Standby Diesel Generator loading. The procedure includes steps i.o secure the Residual Heat Removal pumps with the associated bus loaded and powered by the associate diesel

generator, thus satisfying the requirements for the largest single l load shedding test. The hot automatic start and load sequencing test l requires isolation of both normal and alternate bus feeder breakers, l so that diesel start is initiated by a true bus undervoltage condi-l tion. With this configuration all sequenced loads are picked up by j the diesel generator, subjecting the diesel to maximum starting i

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currents as intended by Regulatory Guide 1.10 Based on the above, this item is close .3 Inspector Follev Items (Closed) Inspector Follow Item (85-35-03), Impact of instrument accu-

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racy tolerance bands on preoperational test acceptance criteria. The inspector reviewed changes included in Startup Administrative Proce-dure 24, Preoperatienal Test Procedure, Format and Instructions, Re-vision 10. The procedure has been revised to require assessment of instrument accuracies or test results, and to properly disposition discrepancies. The inspector will verify proper implementation of the program during future preoperational test results reviews. This item is close (Closed) Open Item (85-27-06), NRR to review allegation pertaining to tailpipe lengths in MK-1 Containment Plant Unique Analysis Repor NRC:NRR document?d their review of this item in Safety Evaluation Report "SER, Mark I Containment Long Term Program, Hope Creek Gener-ating Station" dated October 22, 1985. The allegation was determined to be unsubstantiated and this item is close .4 Construction Deficiency Reports (COR)

(Closed) Construction Deficiency Report (85-00-10), missing lock welds on Anchor / Darling swing check valve The architect / engineer identified a total of sixteen Anchor / Darling 150 lb. and 300 l swing check valves in use at Hope Creek. All sixteen valves were examined. None of the valves had their hinge pin set screws lock welded and several did not have their disc nut retaining pin lock welded or otherwise secured. The applicant has, in accordance with Anchor / Darling recommendations, secured the subject set screws and retaining pins on all valves. The inspector reviewed applicable drawings, work plan procedure records and quality control inspection records (QCIR) to verify that required rework had been performed on all valves and that rework inspection had been accompitshed in accor-dance with program requirement During review of QCIR 1-P-BE-01-3-RV-1.00 the inspector noted that the Quality Control inspector had identified, as an inspection excep-tion, a disc nut which did not have full thread engagement. The QCIR had been closed without disposition of the exception. The inspector question the noted condition. In response to the inspector's concern the applicant contacted Anchor / Darling who provided correspondence stating that valves had been provided with both full hex nuts and half hex nuts, and that thread engagement equal to one half of a hex nut was adequate. The inspector had no further questions. This item is close .

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2.5 IE Bulletins and Circulars (Closed) IE Bulletin 79-24; Frozen Lines. This bulletin was supplied to the licensee for information and no formal response to the NRC was required. The licensee's review of the Hope Creek plant design in-cluding instrumentation, sampling and fire protection lines has iden-tified two safety related pipes which could be subjected to freeze conditions. The two pipes are the High Pressure Coolant Injection /

Reactor Core Isolation Cooling suction line and the Condensate Storage Tank standpipe. Both of these lines are located in a below grade sheltered pit and are provided with heat tracing and insulatio The failure of the heat trace on either of these lines would cause an alarm in the control room. In order to ensure the station's readi-ness for cold weather conditions, Operations Procedure Op-GP-ZZ-003(0)

" Station Preparations for Winter Conditions" is performed each Octobe The scheduling of this OP is controlled by the Inspection Order pro-gra This bulletin is close (Closed) IE Circular 78-16; Limitorque Valve Actuators. This topic will be extensively reviewed as part of IE Bulletin 85-03 titled "Mo-tor - Operated Valve Common Mode Failures During Plant Transients due to Improper Switch Settings". This circular is administrative 1y close (Closed) IE Bulletin 85-02; Undervoltage Trip Attachments on 08-50 Type Reactor Trip Breakers. The inspector reviewed the results of

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the licensee's analyses of this bulletin which verified that no Westinghouse 08-50 or 08-75 breakers are used at Hope Creek. The

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licensee was not required to respond to this bulletin and it is con-sidered close (Closed) IE Circular 81-04; The Role of Shift Technical Advisors and Importance of Reporting Operational Events. The inspector reviewed

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FSAR section 13.1.2.2.3 and verified that the STA's duties and re-sponsibilities listed in the FSAR are incorporated into Administra-tive Procedure SA-AP.ZZ-002(Q) titled " Station Organization and Operating Practices." Administrative guidance appears to be adequate and promotes the effective use of the STA position. All Itcensed operators have received training on reporting events to the NRC. The performance of STAS and the adequacy of operational event reports will be evaluated during future routine inspections. This item is close .6 TMI Action Plan Items (Closed) TAP Item I.A.1.2 and 1.C.3 Shift Super _ visor Responsibilitie In SER section 13.5.1.7 NRC:NRR determined that the Itcensee's de-scribed program and procedures provide administrative controls over i

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activities important to safety and that these controls meet the re-quirements of the above TMI Action Plan items. In addition, the inspector reviewed the following approved procedures and determined

that they provide proper and adequate guidance to the Shift

! Superviso SA-AP-002(Q) Station Organization and Operating Practices OP-AP-002(Q)ConductofOperations l

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l (Closed)TAPItemI.C.5,FeedbackofOperatingExperience. The l

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N'R B RM staff reviewed and accepted the applicants general program in l SER section 13.5.1.7. The inspector reviewed Station Administrative Procedure SA-AP.ZZ-047(0), Operations Administrative Procedure OP-AP.ZZ-105(Q); procedure M 3-POP-001, Operating Experience Review Program; and the Nuclear Department Training Center Administrative Policies Manual. The inspector discussed implementation of the above listed procedures with the applicant representatives. The inspector had no further questions. This item is close , Preoperational Phase Activities 3.1 Plant Tour The inspector toured the control room on day and back shifts. He interviewed operations personnel regarding testing scheduled or in progress, reviewed logs and night orders, and observed alignment and indications of systems undergoing tests. The inspector toured areas of the plant, including drywell, reactor building, and control build-ing. He checked on tests and operations in progress, observed equip- I ment and housekeeping conditions, and Interviewed personnel involved <

in ongoing activitie I 3.2 Preoperational Test Procedure (PTP) Review l The inspector reviewed the following preoperational test procedures to verify that planned testing fully demonstrates that system opera-tion and response meet regulatory requirements and applicant commit-ments. The review also verified applicant review and approval, l proper format, test objectives, prerequisites, initial conditions, test data recording requirements, acceptance criteria and system restoration, j

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PTP-BB-3 (Part A), Revision 0, Standby Diesel Generator Loading

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PTP-88-3 (Part B), Revision 0, ECCS Integrated Initiation / Loss of Offsite Power No violations were identified.

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3.3 Preoperational Test Witnessing The inspector witnessed testing in progress on day and back shifts and verified that 1) testing was conducted using approved procedures by qualified individuals; 2) controlled, calibrated measuring and test equipment was available for required data gathering; 3) adequate quality control coverage was provided; 4) proper coordination between test engineers and operations existed; and, 5) test exceptions and changes were documented and dispositioned properl During the report period the inspector witnessed sections of the fol-lowing preoperational tests:

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KL-1, Primary Containment Instrument Gas;

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SK-1, Leak Detection System;

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AB-1, Main Steam System;

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SV-1, Remote Shutdown Panel;

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KJ-3, Diesel Generator;

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BB-3, (Part A) Standby Diesel Generator Loading; an BB-3, (Part B), ECCS Integrated initiation / Loss of Offsite Powe In addition, the inspector witnessed post preoperational test retest-ing on the following systems:

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BE, Core Spray System

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BD, Reactor Core Isolation Cooling On December 12, 1985 the inspector witnessed portions of PTP-AB-1, Revision 0, Main Steam System. Sections 8.1.16 and 8.1.18, Steam Line A & C Outboard Drain Line Isolation Valves, demonstrate proper valve operation and verify valve stroke time as required by test ac-ceptance criteria. Steps within the sections required leads to be lif ted and jumpers installed in preparation for valve operatio Subsequent to valve operation, steps were included for system resto-ration. Those steps verifying jumper removal and reconnection of lifted leads were designated as Quality Control Mandatory Witness Points (MWP). The inspector noted that on an earlier date the above described preparatory and restorative steps had been performed, but that the verification of proper valve operation and stroke time had not been completed due to valve indication problems, Those MWPs ver-ifying system restoration had been stamped as complete by QC on this earlier date. During the inspector's observation of PTP-AB-1 the steps of Section 8.1.16 and 8.1.18 which had not been successfully completed were reperformed. The steps performed in preparation of, and restoration from the testing, however, were not documented as being reperformed. In order to stroke the valves being tested leads

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t had to be lifted and jumpers installed as described in the tes Because the reperformance of these steps had not been documented,

, Quality Control did not have the opportunity to verify restoration as l required, and the applicable QC mandatory witness points were by- i l passe The inspector questioned the personnel involved and deter-l mined that they were not aware that MWPs had been circumvented.

l 10 CFR 50 Appendix B, Criterton V, Instructions, Procedures, and *

l Drawings requires that activities affecting quality be accomplished

in accordance with approved procedures. Startup Administrative Pro-

cedure (SAP) 24, Revision 10, Section 7.5.2.5 states that for changes in testing sequence, excluding testing sequence changes allowed in

the procedure, the Test Engineer prepares and processes a Change No-

! tice (CN) or On-The-Spot-Change (OTS). Section 8.5.2 of SAP 24 states that retesting is required when maintenance has been performed on equipnent whose operation is an acceptance criterton. It further

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states that for retesting prior to PORC approval, applicable retest-

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ing shall be referenced on the Test Endorsement Record and performed using '.he CN/0T Section 7.5.3.2 of SAP 24 also requires QA approv-al of changes which add, delete or alter a MW Contrary to the above on December 12, 1985 retesting was performed, .

test sequence was changed, and Quality Control Mandatory Witness (

points were deleted without the proper documentation, authorization and approval as detailed in Startup Administrative Procedure 24. The ,

inspector informed the applicant that the above constitutes a viola- i tion of 10 CFR 50, Appendix (85-61-01)

The inspectors expressed concern to startup management regarding the i practice of performing test steps, within a given test section, out :

of sequence. When the order of test step performance within a sec-tion is left to the discretion of the individual performing the test the potential is created for changing test intent, bypassing QC wit-ness points or jeopardizng personnel safety. Intent changes or by- '

passed QC witness points as a result of undocumented test sequence changes may not be identified during results revie l The inspectors noted, during observation of various preoperational I tests, apparent confusion among test engineers regarding retest re- !

quirements and performanc Requirements for performing and docu-menting retest, prior tn PORC test review and approval, are not consistently applied in the fteld. This confusion, combined with the ,

ability to perform test steps out of sequence, could lead to inaccu- '

rate test records or test results of indeterminato qualit I The inspector observed portions of dip-DE-001, Revision 0, Core Spray Loop B Performance Verification. The purpose of the subject testing i was to verify proper sizing uf the Core Spray Loop B discharge re- '

strictive orifice, and to verify adequate loop performance. Further discussion of Core Spray test results is provided in section During the inspector's test observation on November 3,1985 it was ,

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r observed by a PSE&G QC inspector and the NRC inspector that a l non quality bolt had been installed in the Core Spray Pump D dis-charge flange. The inspector examined Quality Control Inspection ,

Record (QCIR) 1-P-BE-01-3A-P-1.1 The QCIR had been completed and l l closed without exception on September 5, 1985. The applicant was (

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informed that this constitutes a violation of 10 CFRR 50, Appendix 0, !

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Criterion V, Instructions, Procedures, and Drawings which states that activities affecting quality shall be prescribed by documented in-structions, procedures or drawings and shall be accomplished in ac-cordance with these instructions, procedures or drawings. Bechtel l

Quality Control Instruction 10855/P-1.10, Revision 8 requires inspec-tion of completed piping system component installation or rework to verify its compliance with applicable design criteri The inspector witnessed portions of preoperational test procedure ;

PTP-BB-3, Standby Diesel Generator Loading (Part A) and ECCS Inte-grated Initiation / Loss of Offsite Power (Part B). This test is de-

signed to demonstrate the following requirements

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The ability of the diesel generators to accept the design base accident electrical loading sequence coincident with a loss of offsite power.

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The ability of the residual heat removal and core Spray systems to automatically realign and inject rated flow to the reactor vessel in response to a loss of Coolant Accident (LOCA).

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Causes of loss of of fsite power (LOP) signal,

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Adequacy of operating procedure ;

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Electrical independence of safety related AC and DC buse The ability of the vital buses to supply power to all required load .

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The ability of the diesel generators to power all ECC5 loads i while at rated flo l l

At the conclusion of this inspection period the test data was being !

accumulated and analyzed by the licensee's test organization. Be- !

cause of the complexity and integrated nature of this test, the in- !

spector intends to review the test results in detail during a future !

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3.4 Preoperational Test Results Review The inspector reviewed test results of PTP-BE-1, Core Spray System, Revision 0, during this inspection to verify that adequate testing had been conducted to satisfy regulatory guidance, licensee commit-ments and FSAR requirements, and to verify that uniform criteria were being applied for evaluation of completed test results in order to assure technical and administrative adequac The inspector verified the licensee's evaluation of test results by review of test changes, test exceptions, test deffetencies, "As-Run" copy of test procedure, acceptance criteria, performance verifica-tion, recording conduct of test, QC inspection records, restoration of system to normal after test, independent vertftcation of critical steps or parameters, identification of personnel conducting and eval-uating test data, and verification that the test results have been approve During review the inspector noted that one of the pressure measure-ment instruments used during conduct of the loop B pump performance testing had been found to be out of calibration. The as-found condt-tion of the instrument was non-conservative in relation to the test data. Data taken using the instrument had been utilized to calculate and plot the loop head / flow curve. Although the instrument had been identified as being out of calibration, test data had not been recal-culated using the more conservative values. The inspector further noted that the calculated value by which pump head exceeds system resistance at maximum flow was 20.6 pst; while the value mistakenly recorded in the body of the test procedure was 25.4/ psi. A minimum dif ferential of 20 pst is required to meet test acceptance criteri The inspector pointed out that if the as-found condition of the pres-sure gauge described above had been applied in the calculations for pump head / flow, it appears that the value by which pump head exceeds system resistance would have fallen below 20 pst, thus not satisfying the test acceptance criteri This condition had gono undetected and an incorrect value of 25.4 pst had been recorded in the test procedur Other pump performance criterla had not been met for loop B and had been identified by the startup group. Due to the deficiencies identi-fled by startup the loop discharge line orifice was resized and the pump performance tests were rerun. This testing was witnessed by the inspectur as described in section 3.3. Review of test results indt-cate that loop performance is now acceptable. The inspector empressed concern that had other loop test acceptance critoria been met satts-factorily the subject failure would have gone undetecte The inspector noted that af ter initial pump suction vortex testing had been completed on all four core spray pumps a now lower torus minimum level during thtudown had been established. A suction vorton test had been conducted on one pump at the new level. The Inspector questioned the applicant as to Wether a single pump test Was ade-quate. The inspector also questioned the applicability of the new torus level during hot shutdown conditions. In hot shutdown the

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i lower level would not ensure adequate pump NPSH. The startup group referred these questions to General Electric and PSE&G site engineer-ing for evaluation. The inspector will carry this review into the next report period to address these question The inspector noted several additional discrepancies which were dis-i cussed with the startup group and resolve . Construction -- Plant Tour and Walk-Through Inspection The inspector periodically toured the plant and performed walk-through inspection during this inspection period. In the walk-through inspection, special emphasis was placed in the areas of drywell, reactor butiding, torus /wetwell, and diesel generator buildings. These inspections we car-

.! ried out to assess the level of general workmanship in the areas of piping and pipe support; effectiveness of cleanliness and housekeeping program;

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and general conformance to project procedures in the work progress and completed wor '

During a tour of the Reactor Dullding on December 14, 1985 the inspector j noted that hanger 1-P-EG-173-H44(0) did not have the required rotatning

clips installe Two retalning clips are required to be installed in grooves machined in the ends of the hanger hinge pin. These clips Ilmit

! hinge pin axial movement, ensuring that the hinge pin remains in place during operation. At the time of the inspection only one of the two re-

! quired clips was installed. The inspector reviewed Quality Control In-

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spection Record 1-P-EG-03-7-P-2.10 and determined that final quality  ;

control inspection had been completed and closed without exception on

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June 13, 198 During a tour of the Drywell, on December 12, 1985, the inspector noted that Main 5 team Line Snubber 1-AB-031-H04(Q) retaining pins had not been r

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properly installe Rotatning pins are to be installed and secured in the snubber hinge pi These retaining pins limit hinge pin axial movement, ensuring that the hinge pin remains in place during operation. Retalning pins had been loosely installed on snubber 1-AB-031-H04(Q) but had not been secured, and could have been inadvertently removed by personnel or j routine piping vibration. The inspector examined Quality Control Inspec-i tion Record 761E965-17-P-Z.10 and determined that final quality control l Inspection of the snubber had been completed and closed without exception i on October 23, 1985,

The inspector informed the applicant that the above examples constitute a violation of 10 CFR 50, Appendix 0 Criterion V which states that activt- -

ties affecting quality shall be prescribed by documanted instructions,

procedures or drawings and shall be accomplished in accordance with these instructions, proceduros or drawings. Hechtel Quality Control Instruction 10855/P-2.10, Revision 12, Inspection of Pipe Support Installation, re-quires inspection of completed pipe supports to verify proper staking, i

) Contrary to the above pipe supports 1-AB 031-H04(Q) and I-P-[0*I73*H44(Q)

) had been successfully inspected by Dechtel Quality Control and did not have staking devices properly installed (85-61-02).

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5. Site Activities 5.1 Project Management Changes On December 2, 1985 the licensee revised the scheduled fuel load date from December 2, 1985 to February 15, 1986 and shifted overall pro-ject completion responsibility from the Vice President - Engineering to the Vice President - Nu.: lear. The Assistant General Manager for Hope Creek operations was assigned the duties of Project Completion Manager. Reporting to the Project Completion Manager is the Startup Manager, Planning and Scheduling Manager, System /Factitty Manager and eight milestone managers. NRC management met with PSE&G management on site to discuss these changes on December 13, 198 .2 Bomb Threats At 9:40 A.M. on December 30, 1985 an unusual event was declared as a result of receiving a bomb threat over the in-plant public address system. The bomb threat stated that a bomb was located on the refu-eling floor of the reactor building (elevation 201). The reactor building was evacuated from elevation 102 ft, to the refuel floor and a bomb search was conducted in accordance with plant security proce-dures. The search did not locate a bomb or any unusual condition The unusual event was terminated at 10:45 A.M. and access was re-stored to all reactor building elevation On January 2, 1986 a bomb threat was received via an outside telephone line. An unusual event was declared at 10:15 A.M. The licensee implemented the security contingency plan and conducted a bomb search with negative results. The unusual event was terminated at 11:28 A.M. Proper notifications were made in both instance . Verification of SER Commitments NRC:NRR has requested NRC Region I assistance in verifying implementation of selected Hope Creek SER (NUREG-1048) commitments. Inspection Report 50-354/85-34 documents the Region I review of a number of these commit-ments, however, the following items remain to be verified. Each item is considered an inspector follow item for administrative purpose Verification of 80% minimum voltage test (SER Section 8.3.1.8)

(354/85-61-03)

- Verification of load acceptance test after prolonged no load opera-tion of D/G (SER Section 8.3.1.10) (354/85-61-04)

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Verification of compliance with position 1 of RG 1.128 on battery ventilation (SER Section 8.3.2.1) (354/85-61-05) ,

- Verification of field confirmatory test of air start system and re-view and approval of test results (SER Section 9.5.6) (354/85-61-06)

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Procedures for monitoring snowfall and snow removal from D/G air in-take and exhaust structures (SER Section 9.5.8) (354/85-61-07)

7. Inspection Program Status Preoperational Test Program Inspection completion status is approximately as follows:

Area  % Inspection Complete Overall Program 70 Procedure Programs Mandatory 100 Primal 100 Test Witness Mandatory 65 Primal 80 Results Review Mandatory 40 Primal 10 Inspection status is consistent with applicant test program progres Operational readiness inspection status is approximately as follows:

Area  % Inspection Complete OPS-Staffing & Procedure 30 Tech Spec Review 100 QA 75 Maintenance 60 Fire Protection 80 Surveillance 100 Rad. Controls 85 Rad. Waste 65 Security 40 Emerg. Planning 75 Additional inspection will be done in each area to verify readiness for fuel loa At the end of this inspection period there were approximately 250 open NRC inspection items including bulletins, circulars, information notices, vio-lations, unresolved items, inspector follow items, construction deficiency reports and TMI action plan items. Approximately 90% of these items re-quire resolution prior to issuance of an operating license and fuel loa The licensee has committed to provide the information necessary to review each item as it becomes available, however the large number of remaining open items will require an increased effort by both the licensee and the NRC to ensure timely resolutio . . - - . - - - _ _ - . - - - _ . _ - - - - - - - - - _ _ _ _ _ _ _ - - - - - -

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8. Exit Interview The inspectors met with applicant and contractor personnel periodically and at the end of the inspection report to summarize the scope and find-ings of their inspection activities. Written material was not provided to the applican Based on Region I review and discussions with the licensee,'it was deter-

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mined that this report does not contain information subject to 10 CFR 2 restrictions.