IR 05000354/1986017

Insp Rept 50-354/86-17 on 860224-28.No Violation Noted. Major Areas Inspected:Maint & Instrumentation & Control Surveillance Procedures.Open Item Identified Re Addition of Permanent Labels on Control & Relay Room Indicators

ML20202E841
Person / Time
Site:	Hope Creek
Issue date:	04/03/1986
From:	Jerrica Johnson, Petrone C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20202E811	List: IR 05000354/1986017 ML20202E808
References
50-354-86-17, NUDOCS 8604140057
Download: ML20202E841 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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Report N /86-17

- Docket N ; License N CPPR-120 Licensee: Public Service Electric and Gas Company 80 Park Plaza - 27C Newark, New Jersey 07101 4 Facility Name: Hope Creek Generating Station Inspection At: Hancocks Bridge, New Jersey Inspection Conducted: February 24 - 28, 1986 Inspectors: (3 db >

C. Petrone, Lead Reactor Engineer S[fd date

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Approved by- t I ta M 4et</ 1/a/gr J'. Johnson, Lntef', Operations Program ~d' ate

Section, 08, DRS i

Inspection Summary: Inspection on February 24-28, 1986 (Report No. 50-354/86-17)

Areas Inspected: Routine announced inspection by a region based inspector of maintenance and I&C surveillance procedures and the implementation of Technical

, Specification Surveillance requirements in these procedures.

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Results: No Violations were identified. One open item was identified regard-ing the addition of permanent labels on control room and relay room indicators,

, gages, meters and controls.

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g 1.0 _ Person Contacted I * Salvesen General Manager - Hope Creek Operations (HCO) -

• Griffith Principal QA Engineer

-* Donges Lead QA Engineer

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• Kudless Maintenance Manager-HC0 ,

. * LaBruna Assistant General Manager - HC0

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• J. Duffy Site Engineering

• A. Klein Startup Coordinator i *J. Fisher Quality Assurance

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• S. Funsten I&C Engineer

*T. Robbins Sr. I&C Supervisor i *L. Rice Senior Staff Engineer ,

• J. Rucki Maintenance Engineer

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NRC

• R. Borchardt Senior Resident Inspector

" Denotes those present at exit meeting on February 28, 1986,

2.0 Instrumentation and Controls Department i

i 2.1 References and Requirements i

CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plant '; Regulatory Guide 1.33, February 1978, Quality Assurance Program Requirement . ANSI N18.7-1976, Administrative Controls and Quality Assurance

. for the Operational Phase of Nuclear Power Plants.

j Technical Specifications Sections 3 and '

i 2.2 Program Review

'i The following administrative and I&C procedures were reviewed to <

determine if the applicant had established an I&C program consistent with the requirements and reference identified in the previous par-l agraph. [It should be noted that the applicants plant procedures and maintenance procedures were reviewed during inspection 50-354/86-02.

', The program for control of Measuring and Test Equipment was reviewed

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during inspection 50-354/85-33].

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3 IC - AP.77-001(Q) Preparation and Approval of I&C Procedures, Rev. 2,

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January 30, 1986. This procedure was comprehensive and well written.

It contains instructions for the preparation, review, approval and revision of all types of I&C pro'cedures including

Device / equipment

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calibration; channel calibration; functional tests; senior calibra-tion; generic procedures, and others. It includes specific, detailed

, . controls and requirements for including post test / calibration return j * to service instructions in all I&C procedures.

IC - AP.77-002(Q), I&C Organization and Responsibilities, Rev. D,

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October 1, 1984. This procedure defines the organization and respon-sibilities of the I&C Engineer, the Senior I&C Supervisor, the I&C Supervisor, the Computer Supervisor, and others. The inspector noted this revision still indicates the I&C Division is part of Technical

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Dapartment, which is no longer true. The I&C Division is now part of the Maintenance Department. The I&C Engineer stated that this, and other I&C procedures, are being revised to reflect this organization- +

al change. However, I&C is still responsible for the inspection, calibration, maintenance, rework, and repair of station instrumenta-tion and control equipment and station computers using approved procedure ! IC - AP.77-003(Q), I&C Document Control and Procedure Review Program, Rev. 1, April 25, 1985, describes I&C document distribution and main-tenance, procedure review, and the interface with the Hope Creek mas-ter cross reference index. It requires that all I&C procedures be reviewed at an interval not to exceed 24 month IC - AP 77-009(Q), Control of I&C Maintenar.ce, Rev. 2, January 26,

! 1986, describes the preparation, processing, and completion of sta-tion work orders for the I&C departmen SA - AP.77-010(Q), Station Preventive Maintenance Program, Rev. 4, January 6, 1986, defines the criteria to be used in determining pre-ventive maintenance requirements for all plant equipment. The pre-ventive maintenance (PM) program shall be implemented using the In-i spection Order (IO) system which will inform the responsible depart-

ment of the details of tasks to be performed. The operability of systems will be maintained by the performance of PM and surveillance tests.

. 2.3 Results: Based on this review the inspector concluded that the licensee has established an effective program for the preparation, review, approval, issue and control of I&C procedures.

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3.0 Surveillance Implementing Procedures 3.1 The inspector selected a sample of surveillance requirements from the

" Final Draft" of the proposed Hope Creek Technical Specifications and performed a review to verify that Technical Specification surveillance requirements had been implemented in the licensees procedures. TS

. Table 4.3.1.1-1, Reactor Protection System Instrumentation Surveil-

• 1ance Requirer.ients was selected for review. This table specifies the functional test and channel calibration requirements for the following functional units: Intermediate Range Monitors: Neutron Flux - High Inoperative Average Power Range Monitor Neutron Flux -

Upscale, Setdown Flow Biased Simulated Thermal Power - Upscale Fixed Neutron Flux -

Upscale Inoperative Downscale , Reactor Vessel Steam Dome l

Pressure - High

- Reactor Vessel Water Level -

Low, level 3 Main Steam Line Isolation Valve - Closure Main Steam Line Radiation -

High Drywell Pressure - High

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5 Scram Discharge Volume Water Level - High

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Float Switch

' Level Transmitter / Trip Unit . Turbine Stop Valve - Closure 10. Turbine Control Valve Fast

, Closure Valve Trip System 011 Pressure - Low 1 Reactor Mode Switch 1 Shutdown Position 12. Manual Scram Based on review of the licensees procedure status lists and discussions

, with cognizant licensee personnel, the inspector determined that the

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licensee had identified and written surveillance procedures (I&C, Main-i tenance, and Operations) to address each Channel Functional Test and j Channel Calibration contained in TS Table 4.3.11-1. The inspector +

also reviewed a printout of the licensees' Inspection Ordor system which is used to schedule the l'icensee's surveillance procedures, i

This review confirmed that all surveillance tests, except one, had

) been scheduled at a frequency which agreed with the interval specified in TS Table 4.3.1.1-1. The one exception was the Channel Function Test for the Scram Discharge Volume Water Level-High float switc The TS specified a frequency of monthly while the licensees ID status had scheduled the test Quarterly. The licensee's representative i stated that the discrepancy was due to a change in the Final Draft of TS. This final draft had been issued the previous week and was still undergoing review by the licensee for other changes. The in-spector reviewed the previous revisions of TS and confirmed that the surveillance frequency had been revised from quarterly to monthl The inspector also reviewed the licensee's program for the identifi- I cation of other T.S. changes and noted that, although there was a l substantial effort yet to be completed, the effort appeared to be '

well controlled.

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3.2 The inspector selected a sample of ten procedures identified above for detailed review. The adequacy of precautions, prerequisites,

, procedure steps, and data tables were evaluated. In addition, the inspector confirmed that the Trip Setpoints and Allowable Values specified in TS Table 2.2.1-1 Reactor Protection System Instrumen-tation Setpoints, had been accurately incorporated in the applicable surveillance procedure. The following procedures were reviewed.

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--IC-FT.SE-006(Q) Functional Test: Nuclear Instrumentation System - Channel B, IRM C51-K601B, Rev. IC-CC.SE-005(Q), Channel Calibration: Nuclear Instrumentation System - Channel A, IRM C51-K601B, Rev. O, October 15, 198 . --IC-FT.AB - 010(Q), Functional Test: Main Steam-Div."2, Channel

• B1, B21-F022A, F022C, F028A, F028C, MSIV Closure Trip Rev. O, August 26, 198 MD-ST.AB-001(Q), Calibration MSIV Closure Trip, Rev. O, February 8, 198 IC-FT.BF-001(0), Functional Test: Control Rod Drive Hydrau-lic - Division 1, Channel AIA, CH-N601A, Scram Discharge Volume High Water Level, Rev. O, October 22, 198 IC-FT.SE-016(Q) Functional Test: NIS - Average Power Range Monitor, Channel D, Rev. O, November 15, 198 IC-CC.BB-035(Q) Channel Calibration: Nuclear Boiler - Division I, Channel A1, 821-N678A, High Reactor Pressure, Rev. O, October 15, 198 IC-FT.BB-023(Q), Functional Test: Nuclear Boiler, Division I, Channel A1, B21-N678A, High Reactor Pressure, Rev. O, October 24, 198 P-ST.SF-003(Q), RPS Manual Scram Test-Monthly Rev. O, January 9, 198 IC-CC.BF-001(Q), Channel Calibration: CRD Hydraulic - Division I Channel C11-N601A, Scram Discharge Volume High Water Leve Results:

In general, the procedures were well written and technically accurat Detailed " removal from service" and " return to service instructions" instructions, including check-off lists and second party verification signatures were provided, were appropriate. Seven of the Ten proce-dures reviewed contained data blanks marked "LATER". The cover sheet on these procedures state that the procedure was approved with the exception of information to be provided and that the procedure is not to be used for actual startup, test, or plant operation until it is

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l l revised to replace all items marked "LATER" with appropriate informa-tion. These procedures will be used to validate the content and in-tent of the procedure until controlled transmittals of Instrument

, Calibration Data (ICD) cards are received from PS Site Engineering

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with the needed "LATER" dat !

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The licensee's management stated that they plan to complete the incor-

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poration of all "LATER" data in the required procedures prior to 11-censing. At the inspectors request, the licensee reviewed the status of all I&C and maintenance procedures and provided the following status to the inspector:

I&C Department Procedures Mode Total Approved Approved Not Yet Required Procedures Procedures W/ Laters Approved

, 1, 2, 3 588 542 251 46

! 4, 5 282 232 95 50

No Mode Impact 330 318 14 12 Totals 1200 1092 360 108 Maintenance Department Procedures Mode Total Approved Approved Not Yet Required Procedures Procedures W/ Laters Approved 1, 2, 3 16 15 0 1 4, 5 38 38 0 0 No Mode Impact 366 356 5 10 Totals 420 409 5 11

The inspector noted that approximately one third of the 282 I&C pro-cedures required for fuel load still contained data to be provided LATER. While the addition of this data is only a small percentage of the work involved in preparing the procedure, it will require a sub-stantial effort to complete prior to licensing. The licensee does, however, have good control of the status of procedure issu .0 Observations of Surveillance Testing Activities On February 26, 1986 the inspector observed the performance of portions of a surveillance functional test IC-FT.BE-00(Q), ADS-Division 2, Logic B, E21-N655F, E11-N655F, Ell-N 656F, by two I&C Technicians. The inspector verified that:

--All prerequisites were completed satisfactory;

--MT&E was calibrated;

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--Required permission was obtained from the licensed Senior Nuclear Shift Supervisor;

--I&C technicians were well briefed, knowledgeable, and very professional;

,- --Procedure steps were followed and signed off as required; and,

--Results obtained met acceptance criteri The inspector witnessed the functional testing of the E21-N655F trip unit and verified that the functional test had been performed successfully. The technicians were able to explain in detail the reasons for the procedure steps and were aware of the importance of procedure compliance. The pro-cedure was well written, complete, and did not require any temporary change However, during performance of step 5.1.9 the inspector noted the indicator light on the front of the control cabinet in the relay room was not labele To identify the indication light the technicians had to open up the door on the back of the relay cabinet and read the label on the backside of the front panel. This same information from the backside of the panel was handwritten in pencil on the front panel. While it is possible to rely on the labels on the backside of the panel it is clear it would be more '

convenient to add these labels to the front panel. In this case, replace the handwritten label with a permanent, controlled labe The inspector discussed these concerns with the I&C Engineer and made a walk through tour of the relay room and control room. During this tour it was noted that numerous panels and meters had handwritten labels added to the front panels as an identification aid during performance of surveil-lance tests. The inspector requested that the licensee review the labeling on instrument panels meters, and gages in the control room and relay room to determine if the labels are adequate to identify switched, gaged, meters, and indicator lights used during surveillance activities. Handwritten labels should be replaced by permanent labels and agree with the designa-tion used in the surveillance and operations procedure At the exit meeting the licensee's management ajreed to implement a pro-gram to review a1d install adequate permanrnt labels on switches, gages, meters, and indicator lights in the control room and relay room. Since these missing labels are generally on back panels and normally used only during the performance of routine surveillance activities; not for plant operation, the inspector agreed with the licensee it would be better to systematically identify these labels during the performance of the sur-veillance tests rather than attempt to institute a crash labeling progra The licensee agreed to complete this re-labeling by completion of power ascension testing. This is unresolved item 50-354/86-17-01.

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5.0 Quality Assurance The inspector reviewed the licensee's Quality Assurance Department involve-ment in the review of I&C surveillance activities. The inspector reviewed the following Station QA Surveillance Reports:

No.85-04, March 4-August 1985,I&CDept.-BalanceofPlant,i&CDevice

Calibration in the Shop and Field; No.85-122, September 24-30 1985, Calibration Control-M&TE, Compliance with Requirements for Controlling Calibration and Issue of Equipment Primarily For Testing; No.86-030, January 6,1986, Calibration Control, Calibration of Drywell Pressure Transmitter; and l

No.86-033, February 1,1986, Calibration of CR0 Hydraulic Control Unit Scram Accumulator Pressure Detector Based on this review, and discussions with QA personnel about the schedul-ing of surveillance activities, the. inspector concluded that the licensee had an active QA program that routinely reviewed I&C department activitie No discrepancies were identifie .0 Management Meetings i l

The inspector discussed the scope of the inspection and presented his findings to the licensee's management personnel at a meeting on February 28, 198 The inspector did not give any written material to the licensee during this inspection.

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