IR 05000354/1986006
| ML20154H778 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 02/26/1986 |
| From: | Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20154H734 | List: |
| References | |
| TASK-1.A.1.1, TASK-2.E.4.2, TASK-2.F.1, TASK-2.K.3.28, TASK-TM 50-354-86-06, 50-354-86-6, IEB-74-14, IEB-77-07, IEB-77-7, IEB-78-14, IEB-80-16, IEB-85-003, IEB-85-3, NUDOCS 8603100373 | |
| Download: ML20154H778 (22) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report N /86-06 Docket 50-354 License CPPR-120 Licensee: Public Service Electric and Gas Company Facility: Hope Creek Generating Station Conducted: January 13 - February 9, 1986 Inspectors: R. W. Borchardt, Senior Resident laspector D. K. Allsopp, Resident Inspector J. J. Lyash, Reactor Engineer E. L. Conner, Project Engineer L. R. Plisco, Resident Inspector, Susequehanna Steam Electric Station A. G. Krasopoulos, Reactor Engineer, Plant System Section ivisiongf Reactor Safety Approved: \/2/Ef8h 2dMBf
. St'rosnider, Chief, Projects Section 1B
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Date Inspection Summary:
Areas Inspected: Routine onsite resident inspection of the following areas:
followup on outstanding inspection items, plant tour, preoperational phase activities, and inspection program status. This inspection involved 410 hours0.00475 days <br />0.114 hours <br />6.779101e-4 weeks <br />1.56005e-4 months <br /> by the inspector Results: This report documents a violation concerning the conduct and results review of preoperational testing (paragraph 4). As discussed in this report and the transmittal letter, the NRC feels that it is imperative that an in- !
depth technical review be performed on all preoperational tests in order to verify that safety related systems are ready for plant licensing and fuel load activitie G603100373 060303 DR ADOCK 0 % y 4 u
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Details 1. Persons Contacted Within this report period, interviews and discussions were conducted with members of the licensee management and staff and various contractor per-sonnel as necessary to support inspection activit . Followup on Outstanding Inspection Items 2.1 Violations (Closed) Violation (85-35-01), Failure to test refueling interlock Immediate corrective actions taken to address the deficiencies iden-tified by the inspector were documented in Inspection Report 85-3 Steps were added to adequately test the items and interlocks de-scribed. At the time the noncompliance was identified the applicant had established a Test Review Board (TRB). The purpose of the TRB is to conduct a detailed technical review of test procedures prior to submission for PORC review. In response to the violation the appli-cant conducted personalized training for TRB members stressing the need to ensure that all test commitments are met and documented. The inspectors noted an increase in the quality of preoperational test procedures since the institution of the TRB. The inspector had no further questions. This item is close (Closed) Violation (85-35-02), Remote shutdown panel alarm and valve testing. The inspector, in Inspection Report 85-35, reviewed changes made to PTP-SV-1 in response to the violation. The applicant has conducted training sessions with the system test engineers emphasiz-ing the need for thorough review of reference document to ensure that the applicable changes are reflected in the approved test procedur In addition, licensing personnel have been advised to route all design / operations FSAR change notices through the Public Service Startup Group for their review and incorporation into test-ing. These actions, in conjunction with the creation of the Test Review Board discussed under item 85-35-01, appear to have increased the general quality of test procedure This item is close (Closed) Violation (85-42-01), Inadequate design control of 125 VDC control power alarms. The inspector reviewed Design Change Package (DCP) 581 which provides 125 VDC annunciator and computer point power from the Bailey logic panel to interrogate unit substation alarms, rather than existing power from the individual unit substa-tion This design change ensures that the control room operator will receive adequate indication of loss of control power to the
Class 1E 480 VAC unit substations. The inspector reviewed Nuclear Department Work Order (WO) 85-11-19-037-6 issued to authorize imple-mentation of DCP 581. This WO was complete, including functional testing of the affected circuits, on January 13, 1986. The applicant
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conducted a design review of alarm circuitry for 7.2KV, 4KV, 480 VAC unit substations and 250 VDC distribution equipment. The inspector reviewed typical configurations for each of the above systems. No additional problems were identified. Based on the reviews conducted, the subject design problem appears to be an isolated case. Corrective action taken in response to the specific problem identified is accep-table. This item is close .2 Unresolved Items (Closed) Unresolved Item (85-24-02), Incomplete Procedure OP-IO.ZZ-008(Q) Shutdown from Outside the Control Room, Revision The above procedure has been reissued and in Revision 0 of the proce-dure a listing of the Remote Shutdown Panel (RSP) redundant instru-mentation has been added. Also added were the steps necessary to actuate the chilled water system. Revision 1 of this procedure in-cludes attachment 8 which incorporates the results of the spurious signal analysis. This attachment provides the steps necessary to trip the HPCI system by closing the turbine stop valve, governor valve and pump discharge valve. This was necessary for the condi-tion when the HPCI high level trip does not function because of a spurious signal. The action described above satisfactorily address-es the NRC concerns and, therefore, this item is resolve (Closed) Unresolved Item (85-24-03), Incomplete Procedure OP-AB.ZZ-135(Q), Loss of Offsite Power, Revision 0. The licensee in Revision 1 of the procedure has included the results of the spurious signal into this procedure. This change includes instructions to manually load and unload the emergency diesel generators to the 4.16 KV vital 1E busses. These actions may be necessary in the event an emergency diesel generator local sequencer malfunctions. The actions taken by the licensee satisfactorily address the NRC concerns. This I item is resolve .3 Inspector Follow Items (Closed) Inspector Follow Item (80-02-03), Mapping of defects in the drywell coating. The inspector reviewed nonconformance report (NCR)
2941. This NCR documents the location and type of defects existing in the drywell coating surface. It further recommends appropriate steps be taken to rework / repair the various types of identified defects. This NCR will track progressing work necessary to complete the remaining drywell coating activitie The inspector has no fur-ther questions. This item is close (Closed) Inspector Follow Item (84-23-01), Enhancement of Instrument Indices - Setpoint. During inspection 84-23 the inspector found that the setpoint register was not complete in that it did not list all instruments which require calibration nor did it have all the re-quired information necessary to prepare calibration cards. A review of this area by region based inspectors and NRC consultants indicates
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that the licensee has developed and implemented a program to correct the setpoint register and calibration program. In general, the setpoints in use were found to be consistent with the design and safety analysis requirements. The area of instrument calibration and setpoint determination will continue to be inspected during future program reviews. This item is close (Closed) Inspector Follow Item (85-14-01), Followup on CRIDS opera-tions phase - administrative controls and computer alarms. The in-spector met with licensee representatives to discuss the final stages of the Control Room Integrated Display System (CRIDS) program devel-opment and the administrative controls used to document changes to the CRIDS data bas The inspector is satisfied that the licensee's program and Site Engineering Instruction 4.2 " Design Change Control" adequately control and document all changes to CRIDS and the CRIDS data base. CRIDS is a non-safety related computer information system which provides plant personnel with plant system information via a number of display screens. The inspector has no further questions at this tim (Closed) Inspector Follow Item (85-14-02), Design changes and devel-opment of operating procedures. The inspector reviewed measures es-tablished by the applicant to ensure that station procedures are consistent with the as-built plant. The applicant has implemented a computer-based design document cross-reference. Prior to issuance of a later design drawing revision this computer cross reference will be utilized to identify all affected procedures. In accordance with Station Administrative Procedures SA-AP-22-003(Q) a departmental re-view of affected procedures is conducted. Due to the high flux of design changes during the preoperational test phase of plant life many change authorizing documents (CAD) may be issued between drawing revisions. The applicant has established a group tn assess CADS is-sued for impact on procedures. These CADS, once field implemented, will be incorporated into applicable procedures. Additional review will be conducted when the CADS are incorporated into a drawing /
document revision in accordance with the system described above. The applicant informed the inspector of plans to assign additional man-power to ensure procedures are updatea and consistent with the as-built plant before fuel load. The inspector concluded that an ade-quate system is in place to ensure accurate plant procedures. The inspector will follow this procedure development / revision process during routine inspections. This item is close (Closed) Inspector Follow Item (85-21-01), Procedures for controlling backlogs, cleanliness, site training, equipment control and retest con-trol. The inspector reviewed the following approved procedures to verify that the identified concerns had been adequately addressed:
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MD-AP.ZZ-009(Q), Revision 2, Control of Station Maintenance
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MD-AP.ZZ-014(Q), Revision 1, Department Personnel Qualification and Training
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OP-AP.ZZ-108(Q), Revision 0, Removal and Return of Equipment to Service
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SA-AP.ZZ-050(Q), Revision 0, Station Retest Program The inspector discussed with applicant operations and maintenance personnel the established system for identifying and correcting main-tenance backlogs, the system for removal / return of equipment to ser-vice, and the system for ensuring adequate retesting. The inspector had no further questions. This item is close (Closed) Inspector Follow Item (85-42-02), Carbon Dioxide Discharge Incident Followup. On January 21, 1986 the licensee briefed the res-ident inspectors and a Region I fire orotection inspector on the car-bon dioxide event which occurred on September 24, 1985. The root cause of the event was determined to be a short circuit across con-tacts on the automatic initiation circuit card. The short circuit was caused by water which had inadvertently entered the electrical boxes during water lancing operations. The licensee has stopped all water lancing, sealed conduit penetrations and placed desicant in the panels to remove moisture. Since the event of September 24, 1985 the CO2 system has completed preoperational testing. The inspector has no further questions at this tim (Closed) Inspector Follow Item (85-56-01), Fire alarm identification and response procedure The inspector reviewed procedures, hard copy alarm information and indices, and drawings available in the control room to assist operators in responding to fir Field fire alarms indicate as alpha numeric designators on a panel in the con-trol room. A computer monitoring system translates the alpha numeric characters into a verbal alarm description. Hard copy indices of the computer supplied information are provided as part of the fire alarm response procedure The alarm response procedures detail required operator actions and reference the applicant's prefire plan. The prefire plan provides additional information regarding specific equipment in each fire are In addition, controlled civil drawings are provided in the control room showing the individual fire areas on each elevation. The inspector also discussed with the applicant the operator training provided in this area. Based on a sampling of the various fire alarm response information and discussion with the oper-ating staff, this item is close (Closed) Inspector Follow Item (85-61-05), Compliance with position 1 of Reg Guide 1.128. A region based specialist reviewed detail test procedure DTP-ZZ-0003, Revision 0, " Battery Room Atmospheric Testing" and verified that it adequately addressed the inspector's concer On January 27, 1986 the performance of portions of this test were witnessed and at the completion of testing a preliminary review of
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the test results was conducted. This review indicated that all ac-ceptance criteria were met as were the guidelines of position C.1 of Reg Guide 1.128 as discussed in SER section 8.3. Any test excep-tions generated during this test will be tracked as part of the preoperational test program results review. The inspector has no further questions and, therefore, this item is close '
(Closed) Inspector Follow Item (85-64-07), 124 Volt DC Quarterly Bat-tery Surveillance Test. The inspector reviewed surveillance proce-dure MD-ST.PK-002(Q) "125 VDC Quarterly Battery Surveillance" and verified that the typographical error identified in Inspection Report 85-64 was correcte The inspector also noted that section 5.2.1 of the surveillance test verifies that the battery room ventilation is operating which by design would limit the hydrogen accumulation in the battery room. The adequacy of the ventilation system is verified during preoperational testing using helium as a test gas. This test was reviewed and found to be in compliance with Reg Guide 1.12 This item is close (Closed) Inspector Follow Item (85-64-08), 4.16 KV system switch and typographical errors. The inspector reviewed on-the-spot change no-tice P-3 tostation procedure OP-SO.PB.001(Q) "4.16 KV System Opera-
tion" and verified that it corrected the typographical errors previously noted. Discussions were also held with members of the licensee's staff. The inspector determined that no other changes were needed to the subject procedur This item is close (Closed) Inspector Follow Item (85-64-10), LPCI Pump Functional Test and Flow Verification. The inspector discussed the licensee's pro-posed resolution of the item with members of the Operations staf The licensee agreed to place the Technical Specification (TS) accep-tance criteria in the body of the applicable surveillance test proce-dures. The followup of this commitment has been designated as an 1.ispector follow item in a separate inspection report (50-354/86-02).
The inspector had no further questions and this item is closed.
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(Closed) Temporary Instruction (25-00-12), Actions Taken in Response to GE SIL No. 402. The substance of this TI and GE SIL No. 402 was also addressed by Information Notice 84-1 The inspector reviewed the applicant's system design and actions taken in response to Infor-mation Notice 84-17. This review is documented in Inspection Report '
85-14 and paragraph 2.4 of this repor This item is administrative 1y close ,
2.4 IE Bulletins. Circulars and Information Notices (Closed) IE Bulletin (74-14), BWR Relief Valve Discharge to Suppres-sion Pool. This bulletin was provided to the licensee for informa-tion and discussed various problems associated with the extended discharge of safety relief valves. The inspector reviewed Technical Specification 3.6.2.1 and abnormal operating procedure OP-AB.ZZ-121
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" Failed Open Safety Relief Valve" to determine that the licensee has addressed the concerns of this bulletin. This item is close (Closed) IE Bulletin (77-07), Containment Electrical Penetration As-semblies at Nuclear Power Plants Under Construction. This bulletin and associated NRC inspector follow item were reviewed and closed in Inspection Report 84-0 (Closed) IE Bulletin (78-14), Deterioration of Buna-N Components in ASCO Solenoids. This bulletin concerns the deterioration through material aging of Buna-N components in CRD scrams pilot valves. The subject was reported in GE Service Information Letters (SILs) 128 (March, 1975), 128 Revision 1 (January, 1976), ano 128 Revision 1, Supplement 1 (August, 1978). The Buna-N service life, including any shelf life, is seven year The inspector reviewed Environmental Qualification Maintenance and Surveillance Information Sheet (EQMS) M-001-SV-021, Maintenance Pro-cedures MJ-AP.ZZ-010(Q) including Attachments 6 and 7, MD-GP-ZZ-033(Q) (Solenoid Valve Maintenance) and MD-PM.BF-005(Q) (Hy-draulic Control Unit Scram & Directional Valve P.M.). EQMS M-001-SV-021 specifies the CRD scram solenoid pilot valves (SSPV)
must be rebuilt with ASCO Replacement Kit FV-186-495 every 5 year The remaining procedures listed above specify 1/3 of the SSPVs will be scheduled for rebuilding every refueling outage and provide the detailed instructions for such rebuildin The inspector had no fur-ther questions regarding this bulletin respons (Closed) IE Bulletin (80-16), Potential Misapplication of Rosemount Models 1151 and 1152 Pressure Transmitters with Either "A" or "D" Output Codes. The subject bulletin was addressed in Inspection Re-port 85-56. It was left open because of 49 Model 1151 transmitters designated by GE as " passive essential safety related (having no electrical safety function because they are passive devices) and a number of Model 1151 transmitters (determined to be 11 by the inspec-tor) designated as nonessential but Q-listed (no safety function)
are in use at Hope Cree The inspector met with licensee engineers and reviewed the control room indications provided by Rosemount 1151 pressure transmitter The licensee's fix is to label control room indications that should not be relied upon during transient / accident conditions. This pro-ject is being performed by Bechtel under Design Change Package (DCP)
No. 711 In a followup inspection outside this report period, the inspector found that implementation in the control room had not commence No scheduling information was provide _
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DCP 7110 needs to be completed prior to initial criticality; it re-mains an outstanding item until unit control room labeling is con-firmed by NRC Region I (50-354/86-06-03). The subject bulletin, however, is close (0 pen) IE Bulletin (85-03), MOV Common Mode Failures During Plant Transients Oue to Improper Switch Settings. The subject bulletin concerns the need to correctly select, set, and maintain the switch setpoints on safety-related motor operated valves (MOVs). For BWRs, the systems involved are HPCI, RCIC and core spray. The bulletin response schedule for plants with a construction permit is two years from the date of the bulleti The inspector reviewed correspondence from Bechtel indicating that the initial response to the NRC will be submitted about May 15, 1986 with detailed information on Item A, regarding the review of the design basis for the operation of each valve, developed after fuel loa (Closed) IE Circular (77-01), Malfunctions of Limitorque Valve Opera-tors. The subject circular addresses the proper setting of torque limit switches and limit switch bypasses, to assure that bypass func-tions are not negated prematurely in the opening or closing cycl This should be verifi;d by procedural requirements to ensure valve operability following maintenance or manual closur The inspector had previously observed Motor Operated Valve Analysis and Testing System (MOVATS) testing of a valve as reported in Inspec-tion Report 85-56, page 13. Two of the tests observed at that time were verification of the torque switch setting, by comparison with a standard load cell, and torque limit switch bypass time, by compari-son of plot of switch operation versus thrust (movement of the worn gear spring pack). It was concluded that MOVATS testing appears to provide an excellent method to ensure proper overall valve operation, and provides solid baseline data for future us This inspection concentrated on procedures necessary to alleviate the circular's concerns. Procedures reviewed were:
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MD-PM.ZZ-004(Q) Revision 1; General Preventative Maintenance for Motor Operated Valves
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MD-GP.ZZ-028(Q) Revision 1; Disassembly and Reassembly of SMB-000 and SMB-00 Limitorque Valve Operators
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MD-GP.ZZ-029(0) Revision 1; Disassembly and Reassembly of SMD-0 to SMB-4 and SB-3 Limitorque
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MD-GP.ZZ-030(Q) Revision 0; Disassembly and Reassembly of SMB-5 and SMB-5T Limitorque Valve Operators
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MD-GP.ZZ-031(Q) Revision 0; Limitorque Valve Operator Inspection and/or Adjustments
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MD-GP.ZZ-050(Q) Station Retest Program In reviewing the above disassembly and reassembly procedures, it was noted that precautions involving backseating and band operation were inconsistent and confusing. Tnese procedures have been revised and are undergoing licensee review at this time. The problems with the precaution section are resolved in the new revisions. The inspector had no further questions on this issu (Closed) IE Circular (79-07), Unexpected Speed Increase of Reactor Recirculation MG Set. The subject circular relates to possible reac-tor power increase caused by unexpected speed increase of the recir-culation pumps resulting from improper troubleshooting of the MG set; in particular, removal of a control fuse from the circuit. Correc-tive actions included review of the scoop tube actuator circuit, a warning statement to be placed in troubleshooting guides, a permanent label to the same effect to be placed on the control panel cover and appropriate training on use of vendor's technical manual. The inspec-tor physically observed the two fuses in the scoop tube actuator cir-cuit, the suggested label on the control panel covers, Bailey product Instructions E 81-2-1 (Electric Control Drive), and the related I&C trainin The licensee's actions are responsive to the circular and, therefore it is resolve (Update) IE Circular (80-16), Operational Deficiencies in Rosemount Model 510 DU Trip Units and Model 1152 Pressure Transmitters. The subject circular was closed out in Inspection Report 85-56 based, in part, by written statement from Bechtel and GE that no Rosemount Mod-el 1152 pressure transmitters are used in safety related systems at Hope Creek. However, during an EQ inspection, site engineering iden-tified two Model 1152 pressure transmitters classified safety related located in the reactor building. As a result of this finding, GE undertook a complete inspection of all Rosemount transmitters sup-plied by them and found one additional Model 115 These Model 1152 pressure transmitters will be replaced prior to fuel loa This update is provided for information; the circular remains close (Closed) IE Circular (81-14), Main Steam Isolation Valve Failures to Closed. This circular provided information on main steam isolation valve (MSIV) failures and recommended that holders of construction permits evaluate system designs to ensure high reliability. The in-spector reviewed the Bechtel analysis of this circular and the sta-tion procedures dealing with the MSIV air supply systems and MSIV maintenance. In addition to operating procedures which ensure a clean air supply, the instrument air system contains filters and dry-ers which are designed to prevent fouling of the MSIV pilot valve This item is close i
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(Closed) Information Notice (84-IN-17), Problems with liquid nitro-gen cooling components below the nil ductility temperature. The inspector reviewed the site specific system design and the appli-cant's response to the notice in Inspection Report 85-14. During this report period the inspector reviewed station operating procedure OP-SP.GS-001(Q), Containment Atmosphere Control System Operatio This procedure requires that an operator be stationed at the vaporiz-er to monitor nitrogen temperatur In addition the inspector veri-fied that the setpoint of the nitrogen temperature controller, which stops nitrogen flow on low temperature, has been raised from -20 degrees F to +40 degrees F. The characteristics of the existing de-sign and the actions taken in response to the notice adequately address the problem. This item is close .5 Construction Deficiency Reports (Closed) Construction Deficiency 81-00-04, Limitorque Valve Operator Problem In June, 1981, the applicant reported a potential signifi-cant deficiency concerning: 1) fiber shims under contact screws; 2)
unidentified terminal blocks; and 3) damaged terminal block in Limitorque valve operators. PSE&G addressed these problems in let-ters dated July 17, 1981 (original report), November 19, 1981, Octo-ber 21, 1982 and March 21, 1983. In essence, the licensee's review found items 2 and 3 above on terminal blocks to not be significan Other defects such as some poor wiring practices included in the re-view. In addition, the applicant expanded the review to include the motor-to-shaft key problem identified in IE Information Notice 81-0 To resolve the concerns given above, PSE&G and Bechtel developed Spe-cific Work Plan / Procedure SWP/P-E-18, " Termination Installation" which included a multi-item inspection checklis To date, 271 Limitorque operators have been inspected and repaired as required including replacing the fiber shim The inspector reviewed a number of inspection checklists and the sys-tem lists of operators that were inspected. In addition, he observed the control of replacement operators in the warehouse where " Hold" tags were placed on all operators not inspected / repaired and a com-puterized listing maintained for contro No problems were identifie (0 pen) Construction Deficiency Report (85-00-10), Missing lockwelds on Anchor / Darling ( A/D) 150 lb and 300 lb swing check valves. The subject CDR identified missing lockwelds on the hinge pin set screw and disc nut retaining pi The hinge pin set screw ensures that the hinge pin will not slide axially, becoming disengaged from the hinge suppor The disc nut retaining pin ensures that the disc nut will not loosen. The fix recommended by A/D, was to stake or tack weld the set screw and pin in plac The applicant implemented this rec-ommendatio The inspector reviewed work plan procedure records and
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quality control inspection records to verify that required rework had been don This inspection was documented and the CDR closed in In-spection Report 85-6 By letter dated December 12, 1985, Anchor / Darling informed Bechtel of additional problems with these same check valves. This letter indi-cates that valves supplied by A/D may be missing hinge support capscrew lockwelds and hinge support to bonnet lockwelds. Disassem-bly and examination of several of the sixteen valves in use at Hope Creek has identified examples of missing hinge support capscrew lockwelds. The applicant plans to reopen and update the original CD Therefore, previously closed outstanding item 85-00-10 is re-opened at this tim During a tour of the maintenance shop, the inspector examined disas-sembled core spray pump discharge check valve V01 This A/D swing check had been removed from the system to facilitate placement of the hinge support capscrew lockweld as described above. The inspector noted that the hinge pin had been removed but that the hinge pin set screw remained secured in place. Examination of the hinge pin showed that it could move freely through the hinge support without contact-ing the set scre The inspector further noted that no hole had been tapped in the hinge pin to receive the set screw and therefore only a friction fit existe The inspector questioned shop personnel and maintenance management and determined that they did not have knowl-edge of the condicio In discussions with the applicant's main-tenance and quality assurance management, the inspector questioned the implementation of apparently inadequate corrective action in response to the original CDR. The hinge pin setscrew had been staked in place, however the friction fit between the screw and hinge pin would not be enough to ensure it's engagement with the hinge suppor The inspector also expressed concern that the applicant had not iden-tified the problem and was not knowledgeable of the problems associ-ated with the original CD .6 TMI Action Plan Items (Closed) TAP Item 1.A.1.1. Shift Technical Advisors. This item was previously reviewed and lef t open in Inspection Report 85-45. During this inspection period the STA course curriculum, the examination and its grading, and the final STA certifications were reviewe There are currently 7 SRO qualified people who have completed the required STA training and 4 non-SRO qualified people who are currently in STA training program. The licensee's STA training programs was found to meet the requirements of this item and, therefore, this item is close (0 pen) TAP Item II.E.4.2, Containment Isolation Dependabilit This item was reviewed by the inspector in Inspection Report 85-4 The issues remaining open at that time concerned qualification /
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control of the primary containment vent and purge valves. To date, the applicant has not qualified these valves to close under accident conditions. The applicant's submittals identified eight unqualified containment vent / purge valves required to be sealed closed in opera-tional conditions 1, 2, and The drywell purge outlet inboard valve may be opened, as discussed in Inspection Report 85-45, to control containment pressure. " Proof and Review" Technical Specifi-cations require these seven valves to be sealed closed and require supplemental leak rate tests on all eight valves to assure no deteri-oration of the resilient seat The inspector reviewed surveillance test procedure OP-ST.GS-002(Q), Drywell and Suppression Changer Purge System Valve Verification - Monthl This procedure describes the tethod by which the valves will be administratively controlled closed, and prescribes the frequency at which the controls will be verified in plac While reviewing system configuration drawings the inspector noted that the nitrogen purge supply line branches and penetrates both the drywell and torus purge inlet lines between their inboard and out-board isolation valves. This nitrogen supply line is isolated by a six inch air operated butterfly valve. Because the line penetrates down-stream of the outboard isolation valve in each purge inlet line, this six inch nitrogen valve is also a containment isolation valv The inspector questioned the applicant as to why this valve had not been discussed in the containment vent / purge valve operability submittals, and requested to review the valve qualification reports. The appli-cant informed the inspector that the nitrogen supply line isolation valve was not qualified. The " Proof and Review" Technical Specifi-cations do not include requirements to seal closed this unqualified valve nor do they address increaseu leak rate test requirements asso-ciated with resilient seat valves. The inspector expressed concern that the valve had not been identified as an unqualified containment isolation valve, and had not been addressed in Technical Specifica-tions or operations procedure The inspector initiated discussion with NRC:NRR regarding the need for inclusion of the nitrogen supply valve in Technical Specificatio This item remains open pending resolution of this issu (Closed) TAP Item II.F.1.6 Containment Hydrogen Instrumentatio This item was reviewed in Inspection Report 85-56 and left open for the following concerns:
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Heat tracing of the sample lines was not complet Installation and removal of the sample line flanges penetrating the drywell top hat area was not addressed in appropriate plant operations and maintenance procedure The inspector verified heat tracing on all six sample lines by in plant inspectio The inspector reviewed system drawings and pro-cedures to ensure installation and removal of flanges are adequately addressed in MD-FR.KE-00Z(Q). This item is close >
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(Closed) TAP Item II.K.3.28 Qualification of ADS Accumulators. NRR reviewed and accepted the ADS system design for long and short term post-LOCA operation in the Safety Evaluation Report Supplement The inspector reviewed the applicant's emergency operating procedures and verified that steps had been included to realign the Primary Containment Instrument Gas (PCIG) system to provide long term make up to the ADS accumulators subsequent to a LOCA. The inspector also reviewed PCIG pressure alarm circuit surveillance test Short term operability of the ADS accumulators is based on their ability to main-tain the stored supply of gas. A total allowable leakage criteria of I scfh ensures this short term operability. Results of industry testing verify that SRV pneumatic operator leakage will not exceed 0.5 scfh. The inspector reviewed the applicant's Inservice Test Plan (IST) concerning leak testing of the accumulators. The inspector noted that only accumulator check valve functional and reverse flow testing were planned, and that no periodic leak testing had been in-cluded. In response to the inspector's concern the applicant initi-ated an amendment to the IST adding ADS accumulator periodic leak rate test requirements. The applicant indicated that the accumulator would be tested to verify that leakage was less than 1 scfh. The inspector pointed out that since SRV pneumatic operator leakage was specified as 0.5 scfh, accumulator leakage must be limited to scfh in order to meet the total allowable leakage I scfh. The appli-cant committed to perform ADS accumulator leak testing to verify leakage less than 0.5 scfh. The inspector will verify implementation in a future inspection (86-06-01). The inspector reviewed the results of PTP-SN-1, Automatic Depressurization System, to verify that the 0.5 scfh accumulator leakage had been tested. Based on the above this item is close . Plant Tour The inspector peri.odically toured the plant and performed walk-through inspections during this perio Special emphasis was placed in the areas of drywell, reactor building, torus /wetwell, and diesel generator build-ings. These inspections were carried out to assess the level of general worknanship in the areas of piping and pipe support; effectiveness of cleanliness and housekeeping program; and general conformance to project procedures in the work progress and completed work. The inspector also tcured the control roam on regular and backshifts. He interviewed opera-tions personnel regarding testing scheduled or in progress, reviewed logs and night orders, and observed alignment and indications of systems under-going tests. He checked on tests and operations in progress, observed equipment conditions, and interviewed personnel involved in ongoing acti-vitie .1 Construction Related Activities During a tour of the reactor building the inspector observed that several bolts on HPCI injection valve (HV-F0006) did not have full
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thread engagement. The valve motor operator and yoke are secured to the valve body by a two piece colla The two collar halves are joined and held in place by four bolt The inspector noted that none of these connections had full stud / nut thread engagement. The inspector reviewed Quality Control Inspection Record (QCIR) 10855/
P-1.10 and observed that the step for verifying full thread engage-ment was designated as not applicable. The inspector questioned the adequacy of the QCIR and the physical condition of the valve. In response to the inspector's concern the applicant initiated deficiency report HQA-86-00 The inspector also identified that sway strut 1-P-BC-019-H24 on the RilR minimum flow line was not supporting the pipe. The inspector examined the applicable hanger design drawing and determined that the hanger should carry a design load of 222 pounds. The as found condi-tion did not comply with this specification as demonstrated by the ability to freely rotate the sway strut body. The inspector also reviewed the final quality control inspection report QCIR C-73-P2.00-2- Final inspection activity 3.4 stating that the pipe support is supporting the pipe, had been signed as complete on October 16, 198 In response to the inspector's finding PSE&G QA initiated DR-HQA-86-00 The inspector noted that the required retaining clips had not been installed on hanger 1-P-FO-224-H0 Retaining rings are installed at each end of the hanger hinge pin to ensure that the pin remains en-gaged with the hinge suppor The inspector observed that QCIR 10855/P-2.10 was reviewed and accepted on June 14, 1985 indicating that this hanger passed its final QC inspection. As a result of the inspector's findings deficiency report HQA-86-003 was writte The inspector pointed out that these examples are similar to those identified in Notice of Violation 85-61-02. The inspector will review the disposition of deficiency report HQA-86-003, HQA-86-004 and HQA-86-005 in conjunction with the referenced violatio (86-06-04)
3.2 Comparison of As-Built Plant to FSAR Description The as-built condition of the High Pressure Coolant Injection (HPCI)
System was checked against the design drawings and descriptions of the systems contained in the FSAR. This comparison consisted of:
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Verification that the latest copies of system field drawings are in agreement with FSAR Process and Instrumentation Diagrams (P&ID's) and description Verification by field observation that component installation, including control and logic instrumentation, is as described in the design drawings and the FSA .
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Identification of equipment conditions and items that might de-grade performanc References used were:
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Bechtel Drawing No. M-55-1, Revision 16, High Pressure Coolant Injectio Bechtel Drawing No. M-56-1, Revision 12, HPCI Pump Turbin FSAR Section 6.3 and Preoperational Test Procedure PTP-BJ-1, High Pressure Coolant Injection Syste The P&ID's in the FSAR are in substantial agreement with the latest field drawings and the as-built condition of the sytems. No viola-tions were identifie . Preoperational Phase Activities 4.1 Preoperational Test Procedure Review The inspector reviewed changes made to PTP-SF-1C and PTP-SF-1 These tests, as originally written, tested response of the RCCS and RWM to various inputs from the Rod Position Information system (RPIs). Due to ongoing Control Rod Drive (CRD) system work, control rods could not be manipulated to establish the required input from RPIS. The applicant, with concurrence from General Electric, is us-ing a GE Nuclear Test Simulator to simulate input from RPIS. The inspector reviewed the affected tests and other CRD system tests on a sampling basis to assure adequate test overlap. It appears that planned testing demonstrates proper functioning of the entire syste .2 Preoperational Test Witnessing The inspector witnessed testing in progress on regular and backshif ts and verified that: 1) testing was conducted using approved proce-dures by qualified individuals, 2) controlled, calibrated measuring and test equipment was available for required data gathering, 3) ade-quate 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 test BB-3(Part A) Standby Diesel Generator Loading
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BB-3(Part B) ECCS Integrated Initiation / Loss of Offsite Power
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KL-1 Primary Containment Instrument Gas
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KP-1 Main Steam Isolation Valve Sealing System
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SA-1 Redundant Reactivity Control
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SF-1 Reactor Manual Control System The inspector also witnessed the following system functional test and post preoperational retestin BD-1 Reactor Core Isolation Cooling
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BF-1 Control Rod Drive System
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DTP-ZZ-0003 Battery Room Ventilation Test During preliminary testing in preparation for PT-BB-3, ECCS Integrat-ed Initiation / Loss of Offsite Power, the applicant identified incon-sistencies in the operation of all four divisions of core spray system initiation logic. In the event of a LOCA the core spray ini-tiation logic is designed to provide a pump start signal 10 seconds after the LOCA signal is received. If the LOCA signal is coincident with a LOP signal the core spray pump start permissive is provided 6 seconds after the corresponding diesel generator breaker closes, and power is returned to the bus. During a dry run of the LOCA with LOP test it was noted that the core spray pump start permissive for each logic division was received 10 seconds from test start, rather than the design time of 6 seconds. Further investigation revealed that one cable in each logic division between the associated 4160 VAC switchgear auxiliary compartment and diesel generator breaker had not been installed. These cables transmit a diesel generator breaker closed signal to their respective core spray pump start circuits, causing the energization of the six second start timer. Because the cables were not present the pump starts occurred only after the LOCA 10 second time dela Bechtel engineering had not scheduled the cables for installation and the cables had not been installed during construction. Component level testing to verify proper installation had been conducted, re-sults reviewed and approved, but had not detected the missing cable The integrated system preoperational test PTP-BE-1, Core Spray Sys-tem, had seen conducted, results reviewed and approved, but had not detected tne condition. PTP-BE-1 as written and run did not ade-quately test the core spray initiation logic in that those logic por-tions utilizing the subject cables had not been included in the test as required by FSAR section 14.2.12.1.7. The inspector informed the applicant that this was a violation of 10 CFR 50 Appendix (86-06-02)
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Also during PTp-BB-3 the applicant identified problems with the Low Pressure Coolant Injection (LPCI) LOCA initiation. During initiation on LOCA with LOP all four LPCI pumps start, with no time delay, sub-sequent to closure of their respective diesel generator breaker During initiation on a LOCA only signal the A and B LPCI pumps should start immediately while the C and D LPCI pumps should start after a five second time dela It was noted during testing that all four LPCI pumps started immediately after simulation of a LOCA condi-tion; no five second delay of the C and D pump start was observe Investigation identified that the two contacts used in the C and D LPCI pump start logic to monitor diesel generator breaker position, had also been used in the C and D Emergency Load Sequencer logic for the same function. This caused cables from the LPCI Start logics and the Emergency Load Sequencer logics to be terminated on a common point at the contacts, resulting in a direct ti This previously unidentified tie between the sequencer and LPCI logic caused a con-tinual diesel breaker closed input to the C and D LPCI logics. These inputs bypass tne LOCA only five second timers, allowing the immedi-ate start of these pumps observed during testing. The applicant documented the problem as a test exception and initiated a Startup Deviation Report (SDR) to correct the proble The inspector noted than numerous problems were encountered during conduct of PTP-BB-3. Several components either did not auto start or did not sequence on at the designed time. During fast bus transfer between offsite sources a number of components tripped off the bu Several logic problems, including the two specific cases described above, were identifie The LOCA/ LOP test is intended to be an inte-grated test of plant response to the design basis acciden The in-spector expressed concern over the number of basic problems encounter-ed in light of the high percentage completion of the involved indivi-dual system preoperational test The inspector will evaluate the problems identified and their resolution during results review of PTP-BB- Preoperational testing of primary containment isolation valves at Hope Creek is accomplished during testing of individual systems to which these valves are assigned. PTP-SM-2 contains a matrix identi-fying the various containment isolation valves, and referencing the applicable system preoperational test. The inspector, during obser-vation of system preoperational tests, witnessed functional testing of numerous containment isolation valve .3 Preoperational Test Results Review The inspector reviewed +est results during this inspection to verify that adequate testing had been conducted to satisfy regulatory guid-ance, licensee commitments 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 r
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For the following tests the inspector verified the licensee's evalua-tion of test results by review of test changes, test exceptions, test deficiencies, "As-Run" copy of test procedure, acceptance criteria, performance verification, recording conduct of test, QC inspection records, restoration of system to normal after test, independent ver-ification of critical steps or parameters, identification of person-nel conducting and evaluating test data, and verification that the test results have been approve BD-1, Revision 0, Reactor Core Isolation Cooling System
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BJ-1, Revision 0, High Pressure Coolant Injection The inspector reviewed the following test to verify that the testing had been conducted utilizing the approved procedure, that results had been approved and that test changes had been properly implemented:
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BH-1, Revision 0, Standby Liquid Control System The inspector reviewed the approved results of PTP-BD-1, Revision 0, Reactor Core Isolation Cooling System. The test as approved contains a total of 139 test exceptions, 44 open exceptions at the time of PORC approva These 44 open exceptions track problems identified during testing, numerous design changes which impact system operation and have not yet been implemented, and several test sections which have not been performed. Thirty seven test change notices and on-the-spot changes were written against the precedure during test-ing. These changes document correction of procedure inaccuracies, changes to reflect the ongoing implementation of design changes and to document the numerous retests performed prior to p0RC approva At the time of the inspector's review fifteen post preoperational test retest packages had been issue The inspector noted that on-the-spot (OTS) changes 32 and 33 docu-mented a large number of test changes made during conduct of the tes The subject changes had been made to the procedure during test conduct without issuance of an OTS. The two referenced OTS were written during the results review process to bring the changes into conformance with the progra The inspector reviewed a sample of the changes addressed by these notices. Section 8.4.15 tests the logic for operation of the RCIC minimum flow valve. The test as written was inadequate, in that the valve auto-open logic was not fully test-ed. A step to verify valve opening under a certain combination of conditions had been included, but steps to simulate these conditions had not. The step verifying valve operation was deleted rather than correcting the test to establish the proper conditions. This dele-tion was made without processing a test change and was later docu-mented on OTS-32 as described abov The inspector examined data gathered during the pump / turbine run and determined that the inter-lock had been functionally demonstrated during operatio '
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Acceptance criteria for operation of the RCIC high steam flow isola-tion timer as stated in the preoperational test is from 2.9 seconds to 3.1 seconds " Proof and Review" Technical Specifications list the requirement as from 3 seconds to 13 seconds. The inspector pointed out to the applicant that these timers would need recalibration to ensure compliance with the Technical Specifications. The inspector further questioned the acceptability of timing a parameter with a small tolerance band using a hand held stop watc In examination of pump / turbine performance data, listed in appendix S to the PTP, the inspector noted that several sets of data had been taken. Measuring and test equipment (M&TE) used to take data during the second run had not been identified. M&TE used during the initial run would have been out of calibration at the time of the second ru The inspector questioned the applicant as to the M&TE used to gather the second set of data. The applicant informed the inspector that a second set of M&TE had been used for the second run but had not been recorded. The applicant produced M&TE usage sheets in support of this statemen The inspector identified two Quality Control Mandatory Witness Points (MWP) which had not been completed by QC, and had not been identified during results revie Steps 8.16.3.31.A and 8.5.2.17.b were desig-nated as MWP but had not been stam;.ed as verified by QC. In response to the inspectors concern the applicant's OC personnel verified prop-er restoration in accordance with che step The inspector noted Test Exception 98 had been dispositioned by issu-ance of OTS 31. Testing under OTS 31 had not been completed. Test exception 98 was not listed as open and no SDR had been referenced as
' tracking this retest. In response to the inspector's question the applicant produced SOR BD-445 which had been written to implement OTS-31. The inspector pointed out that proper documentation of open test exceptions is required to ensure proper completion and adequate review of all test result The excessive number of test exceptions and test changes associated with this and many other tests makes a technical review of test results difficult for all partie Inconsistency in application of program requirements in the area of documenting test exceptions, test changes and retesting makes interpretation of test results heavily dependent on the individual test engineers. The number of design changes being implemented after completion of the preoperational test and the amount of retest / test deferral as a result of incomplete system status requires an especially deliberate approach to the test results review proces The inspector reviev,ed the results of PTP-BH-1, Standby Liquid Con-trol, to verify that testing had been conducted in accordance with the approved procedure and that results had been reviewed and ap-proved in accordance with the program. The inspector reviewed the 24
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on-the-spot (OTS) changes to the procedure. OTS-5 resulted from a major change to the logic; deleting the LOCA/ LOD process start inhib-it and sequencer start signal The inspector reviewed the change and the package and found no unacceptable condition The inspector reviewed the High Pressure Coolant Injection test re-sults package (PTP-BJ-1) and verified the licensee's evaluation of test results by review of test changes, test exceptions, record copy of the test procedure, acceptance criteria, performance verification, recording conduct of test, independent verification of critical steps or parameters, identification of personnel conducting and evaluating test data, and verification that the test results had been approve The following items were noted in the test results revie Test Exception (TE) 45 stated that valve BJ-HV-8278 did not meet the opening and closing time acceptance criteria of GE Specification 22A6237. The test procedure required the valve to open and close in less than 20 seconds, but during the test the valve opened and closed at greater than 20 seconds. The HPCI system is designed to inject rated flow into the reactor vessel in 25 seconds. The FSAR, in Table 6.3-2, states that the maximum allowed delay time from ini-tiating signal to rated flow available and injection valve wide open is 25 second In GE letter GB-85-246, included in the test package, a stroke time of less than 44 seconds was approved as long as the HPCI flow split is satisfactory and the full flow injection time is less than 25 seconds from HPCI initiation. The test exception was dispositioned to perform the actual demonstration during the power ascen-sion testing program and is tracked by SDR-BJ-368. If the acceptance criteria are changed following the power ascen-sion testing, an FASR change may be require Test Exception (TE) 105 stated that the data taken for the ccmbined pump capacity performance curve did not support the design performance curve. Since only auxiliary steam was available for the preoperational test, the TE was dispositioned to perform the performance curve in the power ascension program. The item will be tracked in SDR-BJ-44 The resolution of the noted Test Exceptions will be reviewed follow-ing the startup program testin The inspector concluded the review of PTP-BE-1, Core Spray System, begun in Inspection Report 85-61. The inspector discussed with Gen-eral Electric and PSE&G site engineering the acceptability of con-ducting a single pump vortex test. System configuration and similarity indicates that a single retest would be representative of the remaining loops. The inspector reviewed the " Proof and Review" copy of Technical Specifications to verify that the applicant's re-quested lower torus water level limit is applicable only in cold shutdow F
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21 Inspection Program Status Preoperational Test Program Inspection completion status is approximately as follows:
Area % Inspection Complete Overall Program 80 Procedure Programs Mandatory 100 Primal 100 Test Witness Mandatory 75 Primal 100 Results Review Mandato ry 46 Primal 60 Inspection status is consistent with applicant test program progres Operational readiness inspection status is approximately as follows:
Area % Inspection Complete OPS Staffing & Procedure 90 Tech Spec Review 100 QA 100 Maintenance 60 Fire Protection 100 Surveillance 100 Rad. Controls 85 Rad. Waste 70 Security 100 Emerg. Planning 90 Additional inspection will be done in each area to verify readiness for fuel loa . Exit Interview The inspectors met with applicant and contractor personnel periodically and at the end of the inspection period to summarize the scope and find-ings of their inspection activities. Written material was not provided to the applicant during the exi During the course of this inspection, the licensee was provided written listings of NRC open items from previously issued inspection reports. All of the information provided in the open item list was obtained from pub-licly available issued inspection reports and was provided to the licensee in order to more effectively address outstanding NRC concern I l
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Based on Region I review and discussions with the licensee, it was deter-mined that this report does not contain information subject to 10 CFR 2 restriction J