IR 05000354/1986053

Insp Rept 50-354/86-53 on 861027-31.Violation Noted:Licensee Changed Initial Startup Test Program Described in FSAR Section 14 by Performing Test TE-SU.SV-281 in Test Condition 1 Rather Test Condition 2

ML20214V372
Person / Time
Site:	Hope Creek
Issue date:	11/17/1986
From:	Florek D, Wink L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214V337	List: IR 05000354/1986053 ML20214V332 ML20214V349
References
50-354-86-53, NUDOCS 8612090653
Download: ML20214V372 (13)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

l Report No. 50-354/86-53 Docket N !

License No. NPF-54 L

Licensee: Public Service Electric and Gas Company l 80 Park Plaza

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l- Newark, New Jersey 07101 Facility Name: Hope Creek Generating Station, Unit 1

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Inspection At: Hancocks Bridge, New Jersey Inspection Conducted: October 27-31, 1986 1 /

Inspectors: h M/ ~~

l L. U nk, Reactor En'g'theer

/ dpte Approved by: 4 -

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0; FloreK, Chief, fest Programs Section, b<

(dape 08, DRS Inspection Summary: Inspection of October 27-31, 1986 (Inspection Report l No. 50-354/86-53)

i l Areas Inspected: Routine, unannounced inspection of the overall power

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ascension test program including procedure reviews, test witnessing and test results evaluation, independent measurements and verifications, QA/QC interface and followup of licensee action on previous inspection findings.

! Results: One violation was identified involving failure to comply with a license condition. (See Section 3.2)

NOTE: For acronyms not defined refer to NUREG 0544 " Handbook of Acronyms and Initialisms."

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DETAILS 1.0 Persons Contacted Public Service Electric and Gas Company (PSE&G)

J. Adams, Power Ascension Technical Reviewer G. Chew, Power Ascension Technical Reviewer P. Dempsey, Shift Test Coordinator

• M. Farschon, Power Ascension Manager B. Forward, Power Ascension Administrative Coordinator

• A. Giardino, Manager-Station Quality Assurance (QA)

• R. Griffith, Sr., Principal Engineer-QA

• C. Johnson, General Manager-Nuclear QA

• P. Krishna, Assistant to the General Manager-HC0

• C. McNeill, Jr., Vice President-Nuclear

• J. Nichols, Technical Manager-HC0 S. Pope, Shift Test Coordinator

• R. Salvesen, General Manager-HC0 W. Schell, Power Ascension Technical Director E. Skeehan, General Electric Operations Manager W. Thomas, Shift Test Coordinator

• C. Vondra, Operating Engineer U.S. Nuclear Regulatory Commission D. Allsopp, Resident Inspector

• R. Borchardt, Senior Resident Inspector

• T. Johnson, Senior Resident Inspector-Peach Bottom

• A. Luptak, Senior Resident Inspector-FitzPatrick

• G. Napuda, Lead Reactor Engineer

• L. Norrholm, Chief, Reactor Projects Section No. 2B

• Denotes those present at the exit meeting on October 31, 1986. The inspector also contacted other members of the licensee's staff including senior nuclear shift supervisors, reactor operators, test engineers and members of the technical staf .0 Licensee Action on Previous Inspection Findings (Closed) Violation (354/86-35-01) Use of a power ascension procedure inappropriate to the circumstances. The licensee took immediate corrective action at the time the procedural deficiency was identified by the inspector. During the current inspection it was determined that all other similar test procedures had been modified, as necessary, prior to their performance. The inspector concluded that the licensee's corrective actions for this violation were acceptabl .

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(Closad) Violation (Fa /86-35-02) Failure to follow a written power ascension test procedure and failure to adequately review the result During the review of power ascension test results packages in this, and previous inspections, the inspector has confirmed that licensee personnel have improved their performance in these areas. It was also confirmed that additional personnel had been assigned to perform independent re-views of the test results. Since no additional instances of deficiencies in these areas have been noted, the inspector concluded that the li-censee's corrective actions were acceptabl (Closed) Unresolved Item (354/86-35-03) Minimum temperature limit. in the Dyrwell Undervessel area. The inspector reviewed the results of power ascension test TE-SU.GT-721, Drywell and Steam Tunnel Cooling System Normal Operation Performance Test, conducted on October 15, 1986 including a letter from the General Electric Hope Creek Project Manager dated October 24, 1986 titled " Hope Creek Project RPV Skirt Temperatures" which transmitted an analysis of the result The inspector noted that actions taken by the licensee had achieved the desired results of limiting the temperature variations in the drywell. The General Electric analysis of the test data for the RPV skirt indicated a maximum fatigue usage factor (at the skirt knuckle to bottom head junction) of .029 which is well within +.he code limit of 1.0 based on a 40 year operating lif The inspector had no further concerns in this are .0 Power Ascension Test Program (PATP)

3.1 References

Regulatory Guide 1.68, Revision 2, August 1978, " Initial Test Programs for Water-Cooled Nuclear Power Plants"

ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants"

Hope Creek Generating Station (HCGS) Technical Specifications, Revision 1, July 25,1986

HCGS Final Safety Analysis Report (FSAR), Chapter 14, " Initial Test Program"

HCGS Safety Evaluation Report (SER), Chapter 14, " Initial Test Program" Station Administrative Procedure, SA-AP.ZZ-036, Revision 3,

" Phase III Startup Test Program"

Specification NE80 23A4137, Revision 0, " Hope Creek Startup Test Specification

HCGS Power Ascension Test Matrix, Revision 8

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3,2 nuorall power Awandan Toe + Drocram Discussion The inspector held discussions with various members of the PATP staff to assess the overall status of the test program and the test results review. All test results for Test Condition 2 have been formally accepted by licensee management. Testing activities were continuing in Test Condition 3 with the critical path activities being the tuning of the HPCI system and the resolution of the sluggish behavior of the "B" Recirculation Pump M-G set on a runback demand (see discussions in paragraph 3.4).

On October 29, 1986 the inspector attended the Technical Review Board review of a series of three HPCI tests performed under Power Ascension Test Procedure TE-SU.BJ-152, High Pressure Coolant Injec-tion System - RPV Injection. These tests were run in an attempt to resolve the Level 1 acceptance criterion failure for HPCI time to rated flow (see discussion in paragraph 3.5). The review involved verification of conformance to acceptance criteria, review of results deficiencies (RDFs) and resolution of independent reviewer comments. The board discussed general plans for further tuning and testing to resolve the problem of HPCI response time and addressed the scope of retesting required following any tuning of the syste The inspector also followed up on a concern expressed by the Augmented Inspection Team (see Inspection Report No. 50-354/86-50) on the adequacy of the administrative controls to insure conformance with License Condition C(10). This license condition allows changes to be made in the PATP, as described in the FSAR, in accordance with the provisions of 10 CFR 50.59, Changes, Tests and Experiments. The inspector held discussion with the Power Ascension Manager and the

Power Ascensfon Technical Director to review the administrative controls in this are In addition, the inspector reviewed six (6)

changes made to the PATP under the provisions of 10 CFR 50.59 to assess conformance with the license conditio The inspector determined that the PATP had no formal procedure to insure conformance with the license condition. Changes were made using guidance provided in a memo dated May 2, 1986 from the Manager-Licensing and Regulation titled "HCGS Control of FSAR Changes". The memo did not provide guidance on the level of review and approval required to make a change to the PATP and did not address the timeliness and extent of the review. The inspector discussed this memo with the Manager-Licensing and Regulation and determined that the memo had not been intended to insure conformance with the license conditio {

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During the review of the six changes to the PATP the inspector found ..

that the documented bases for the changes were lacking in the detail required to fully justify that an unreviewed safety question was not involved. In addition, during the review of Change PA-8, which changed the order of testing to allow performance of the Remote Shutdown Test, TE-SU.SV-281, in Test Condition 1, and deferred the Loss of Power Test, TE-SU.ZZ-311, Until Test Condition 2, the inspector found that a written safety evaluation was not performed until three days after the change was made and that the change was not submitted to the NRC within the required one month. Change PA-8 was implemented on August 22, 1986 when the Remote Shutdown Test was performed in Test Condition 1, tne safety evaluation was documented on August 25, 1986 and submitted to the NRC on October 2, 198 This is considered a violation (354/86-53-01).

The inspector also reviewed the corrective actions that the licensee has initiated to correct these deficiencies. On October 1, 1986 the Station Operations Review Committee directed that all changes made to the PATP be transmitted to Nuclear System Engineering for review in accordance with Site Engineering Instruction 4.6, Safety and Environmental Evaluations. The inspector reviewed the safety evaluations provided by Nuclear System Engineering and cor.cluded that they were adequate to meet the requirements of 10 CFR 50.59 and that the changes made to the PATP did not constitute an unreviewed safety question. In addition, the inspector reviewed draft pro-cedure SE-AP.ZZ-100, Safety Evaluation Preparation, and concluded that it would provide adequate administrative controls to insure conformance with the requirements of 10 CFR 50.59 and the license conditio Findings One violation was identified for failure to comply with License Condition C(10).

3.3 Power Ascension Test Procedure Review Scope The Power Ascension Test Procedures lir.ted in Attachment A were reviewed for their conformance to the requirements and guidelines of the references in Paragraph 3.1 and for the attributes previously defined in Inspection Report 50-354/86-0 Findings No unacceptable conditions were identified.

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3.4 power Ascension Test Witnessing

' Scope The inspector witnessed the performance of the power ascension tests listed in Attachment B and discussed below. The performance of these tests were witnessed to verify the attributes previously defined in Inspection Report 50-354/86-3 Discussion TE-SU.BJ-152. This test was performed to demonstrate the operability of the HPCI system following the failure of the system to achieve rated flow within the required 27 seconds during a cold quick start to the reactor pressure vesse The failure of the cold quick start was thought to be due to a less than optimal system tuning coupled with the slow draining of hydraulic actuating fluid as the system sat idle. To maintain HPCI system operability while plans were formulated to correct these problems it was proposed to run the system's auxiliary oil pump every eight hours to counter the hydraulic fluid drainage. To demonstrate that this was acceptable, the HPCI system had been allowed to sit idle for twelve hours before the performance of this test. The test was successfully performed and HPCI achieved rated flow in 26.5 second TE-SU.AE-235. This test was performed to demonstrate adequate tuning of the feedwater system and acceptable stability to both large and small feedwater flow steps. The inspector witnessed the performance of large flow step testing with the A feedwater pump in manual, to induce the flow step, and the B and C feedwater pumps in automatic. It was noted that the feedwater system was very responsive to induced flow changes and that overall system response was very stable and well dampe TE-SU.BB-35 The inspector witnessed various data taking activities on recirculation flow instrumentation to suppori the computer analysis (JR PUMP) of the recirculation flow calibration verificatio IC-GP.BB-001. This procedure was performed to trouble shoot the cause of the sluggish behavior of the B recirculation pump upon a runback demand. Following the instrumentation of the runback circuitry and the control for both the A and B recirculation pumps, a runback was initiated by simulating a feedwater pump trip and lowering levels to the runback setpoint. The inspector monitored recirculation system performance during the test and verified the anticipated anomalous behavior of the B recirculation pum The test was successful in that differences in the behaviors of the two pumps were localized. At the conclusion of the inspection a vendor representative was on site to help to resolve the proble The inspector will review the actions taken to resolve this problem during a future routine inspectio . . _ - - - - _ - - - - . - - . - - . . _ --_

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IC-LC.BJ-002. The inspector witnessed portions of the HPCI turbine controller tune-up performed to address the problem of HPCI response time discussed above. The inspector also monitored operations performance during this test to determine if actions required by Technical Specifications were being followed. Following completion of this tune-up and the tune-up of the HPCI flow controller a hot quick start test was performed and the time to rated flow was measured to be 22.9 seconds, 3.6 seconds less than before the tune-up and well within the acceptance criterion of 27 seconds. The in-spector will review the results of the Cold Quick Start Testing in a future routine inspectio Findings No unacceptable conditions were note .5 Power Ascension Test Results Evaluation Scope The power ascension test results listed in Attachment C were eval-uated for the attributes identified in Inspection Report 50-354/

86-24. A summary of significant test results and identified test results deficiencies is provided in the discussion belo Discussion TE-SU.BB-262. This test was performed in conjunction with TE-SU ZZ-311, Loss of Offsite Power, on September 11, 1986. The test monitors the performance of the SRVs during plant trips to assess proper functioning (including the Lo-Lo Set Function) and reseating. All acceptance criteria were satisfie TE-SU.AB-341. This test was performed in conjunction with TE-SU.ZZ-311, Loss of Offsite Power, on September 11, 1986. The test monitors the dynamic response on the main steam piping inside the drywell during plant trips and SRV actuations. All acceptance criteria on pipe vibration were satisfie TE-SU.ZZ-761. This test contains no acceptance criteria. It verifies the proper functioning of the data collection devices on the Torus and establishes calibration and range setting prior to the performance of TE-SU.ZZ-762, Confirmatory In-Plant Test of SRV Dis-charge. The test identified numerous instrumentation problems that would prevent the successful completion of TE-SU.ZZ-762. Work orders '

were issued to troubleshoot and calibrate these instruments and the work was completed during the outage prior to entering Test Condition TE-SU.BF-054. This test was performed in conjunction with the planned scram during the Loss of Offsite Power, TE-SU.ZZ-311, on October 11, 1986. The scram times of the four selected rods s

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(coordinates 26-23, 42-15, 50-47 and 54-19) were measured and verified to be well within the acceptance criterion and technical specification limit of 7.0 second TE-SU.BJ-152. This test was performed three times between October 22 and October 24, 1986. The first run satisfied all acceptance criteria with the exception of time to rated flow (2 seconds vs. a 27 second limit). The second run also failed to achieve the required time to rated flow (28.9 sec). Prior to the third run an adjustment was made to the ramp gen < rator (ramp time decrease from approximately 11 seconds to 7 seconds) and the time to rated flow was measured to be 26.2 seconds. Further discussion of the efforts involved with the HPCI testing can be found in para-graph TE-SU.BB-221. This test was performed at 18.7% to resolve a results deficiency (RDF #88) identified in Test Condition 1 and discussed in Inspection Report 50-354/86-43. The test demonstrated adequate transient response of the pressure regulator with the main turbine on-line. All acceptance criteria were satisfie TE-SU.BB-262. This test was performed in conjunction with TE-SU.ZZ-311, Loss of Offsite Power, on October 11, 1986. All acceptance criteria were satisfie TE-SU.ZZ-311. This test was performed at approximately 20% of rated thermal power on October 11, 1986 to resolve Level 1 and Level 2 acceptance criteria failures identified during the initial performance of this test on September 11, 1986. All acceptance criteria were satisfie TE-SU.AB-331. This test was performed at approximately 55% of rated tnermal power to verify that the steady state vibration of the main steam piping inside the drywell is within established limits. All acceptance criteria were satisfie TE-SU.GT-721. This test was performed at approximately 54% of rated thermal power to verify that average drywell air temperature and certain local air temperatures are within limits. A Level 2 results deficiency was identified for six points where the temperature exceeded 150 All other acceptance criteria were satisfied. The inspector noted that the temperature distribution in the drywell and the number of points exceeding 150 F had been significantly improved since the performance of this test in Test Condition Heat-up. The licensee has scheduled additional corrective action, including adJitional insulation and modifications to the Drywell HVAC system, for a future outage. The inspector will followup the results of these modifications during a future routine inspectio {

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TE-SU.GT-724. The acceptance criterion for maximum drywell shield wall concrete temperature was satisfied at 49*; of rated thermal powe TE-SU.EG-751. This test was performed to verify SACS heat exchanger capacity. The Level 1 acceptance criterion (> 132.5 M3TU/HR) was satisfied, however a Level 2 acceptance criteria failure (RDF #130)

occurred for both single and dual loop operations. The results are summarized below:

LOOPS MEASURED CAPACITY LIMIT A 166.9 MBTV/HR > 201.4 MBTU/HR B 161.5 MBTU/HR 5 201.4 MBTV/HR A and B 328.5 MBTU/HR E389.3MBTU/HR TE-SU.AB-793. Baseline data was obtained for SRV H, the only SRV which lifted, during the performance of the Loss of Power Test, TE-SU.ZZ-311, on October 11, 198 FINDINGS No unacceptable conditions were identifie .0 Independent Measurements and Verifications The inspector performed multiple independent measurements and verifica-tions of HPCI response time, recirculation system flow unit square rooter output voltages and feedwater system stability during flow changes during the witnessing of power ascension testing (paragraph 3.4). In addition, during the evaluation of test results (paragraph 3.5), the inspector veri-fied the licensee's determination of conformance to acceptance criteria for main steam piping vibration, HPCI system response times, speed peaks, and decay ratios and drywell and containment temperatures. The inspect-or also independently calculated the heat removal capacities of the SACS heat exchangers. In all cases the inspector's measurements, verifica-tions and calculations agreed with those of the license No unacceptable conditions were note .0 QA/QC Interface with the Power Ascension Program During the course of witnessing power ascension tests, the inspector observed QA engineers performing surveillances. The inspector also noted during the evaluation of power ascension test results that the test results packages had been reviewed by QA engineer No unacceptable conditions were note (

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6.0 Exit Interview At the conclusion of the site inspection on October 31, 1986, a joint exit meeting was conducted with the Operational Assessment Team (In-spection Report No. 50-354/86-52) and the licensee's senior representa-tive on site (denoted in paragraph 1.0).

At no time during the inspection was written material provided to the licensee by the inspector. Based on the NRC Region I review of this report and discussions with the licensee representatives during the inspection, it was determined that this report does not contain infor-mation subject to 10 CFR 2.790 restriction _

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POWER ASCENSION TEST PROCEDURES REVIEWED

.TE-SU.AE-232 Feedwater System Loss of Feedwater Heating Test, Revision 1, approved October 20, 1986 TE-SU.BB-342 Recirculation System Piping Dynamic Response, Revision 1, approved June 24, 1986 TE-SU.BB-351 Recirculation System Flow Calibration Verification, Revision 2, approved June 25, 1986 TE-SU.BB-352 Recirculation System Maximum Flow Limit Verification, Revision 1, approved February 17, 1986

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• . ATTACHMENT B

POWER ASCENSION TESTS WITNESSED Tt-SU.BJ-152 High Pressure Coolant Injection System - RPV Injection, performed October 28, 1986 TE-SU.AE-235 'Feedwater System Manual Feedwater Flow Step Change Test, performed October 28, 1986 TE-SU.BB-351 Recirculation System Flow Calibration Verification, performed October 29, 1986 IC-GP.BB-001 Recirculation Pump Runback Adjustment Verification, performed October 28, 1986 IC-LC.BJ-002 Loop Calibration - HPCI Turbine Controller Tune-up, performed October 30, 1956

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e ATTACHMENT C

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POWER ASCENSION' TEST RESULTS EVALUATED

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TEST CONDITION TWO TE-SU.BB-262 Relief Valve Response During Major Trip Revision 2, completed September 12, 1986, results accepted October 24, 1986 s TE-SU.AB-341 NSSS Main Steam Piping Dynamic Response, Revision 3, completed September 12, 1986, results accepted October 24, 1986

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TE-SU.ZZ-761 In plant Safety Relief Valve Shakedown Test, Revision 4, completed September 11, 1986, results accepted October 25,1986 TEST CONDITION THREE TE-SU.BF-054 CRD System Scram Testing During Planned Scrams, Revision 7, completed October 11, 1986, results accepted October 29, 1986 TE-SU.BJ-152 High Pressure Coolant Injection System - RPV Injection, Revision 6, Run #2 completed October 22, 1986, Run #3 completed October 24, 1986, Run #4 completed October 24, 1986, results not yet accepte TE-SU.BB-221 Pressure Regulator Test - Control Valves Controlling, Revision 8, (Retest from TC-1)

completed October 14, 1986, results accepted October 30, 198 TE-SU.BB-262 Relief Valve Response During Major Trips, Revision 3, completed October 11, 1986 results accepted October 29, 1986 TE-SU.ZZ-311 NSSS Main Steam Piping Steady State Vibration, Revision 3, completed October 15, 1986, results accepted October 29, 1986 TE-SU.GT-721 Drywell and Steam Tunnel Cooling System Normal Operation Performance Test, Revision 5, completed October 15, 1986, results not yet accepted '

TE-SU.GT-724 Containment Penetration Cooling Normal Operation Performance Test, Revision 2, completed October 11, 1986, results accepted October 29, 1986 TE-SU.EG-751 Safety and Auxiliary Cooling System Operational Performance Test, Revision 3, completed October 17, 1986, results not yet accepte TE-SU.AB-793 Safety Relief Valve Acoustic Monitor Baseline Data, Revision 4, completed October 11, 1986, results accepted October 30, 1986