IR 05000354/1989013

Insp Rept 50-354/89-13 on 890626-30.No Violations Noted. Major Areas Inspected:Licensee Compliance to 10CFR50.62 ATWS Rule Pertaining to Alternate Rod Injection Sys

ML20247N456
Person / Time
Site:	Hope Creek
Issue date:	07/20/1989
From:	Blumberg N, Oliveira W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20247N454	List: IR 05000354/1989013 ML20247N448
References
50-354-89-13, NUDOCS 8908020402
Download: ML20247N456 (8)

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'U.S. NUCLEAR REGULATORY COMMISSION

REGION I

l Report N /89-13

. Docket N License N NPF-57 Licensee: -Public Service Electric and Gas Company Post Office Box 236 Hancocks Bridge New Jersey 08038 Facility Name: Hope Creek Generating Station Inspection At: Hancocks Bridge and Salem, New Jersey Inspea. tion Dates: June 26-30, 1989

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Inspector:

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Oliveira, Reactor Engineer, OPS, OB, 20 ['9

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DRS, Region I i Approved by: , , 0.4,ut4 2d/V7 N.J.Blumberg, Chief,OperaffonalPrograms / Date Section, Operations Branch, URS, RI Inspectiot, Summary: Routine announced inspection on June 26-30,1989 (Report i No. 50-354/89-13)

Areas Inspected: Review of the licensee's compliance to the 10 CFR 50.62 Anticipated Transient Without Scram (ATWS) Rule as it pertains to the Alternate Rod Injection (ARI)-syste {

Results: The ARI system was installed during the construction of the Hope '

Creek Generating Station (HCGS) and was eccepted in the NRC Safety Evaluation Report (SER) of October 14, 1987. The minor design changes made to the ARI system since its initial installation do not affect compliance to the ATWS Rul Verification of the ARI system compliance to the ATWS Rule completes the NRC review of the licensee's actions to implement the requirements of the NRC Temporary Instruction (TI) 2500/2 No violations or deviations were identified and TI 2500/20 is close FDR ADOCK 05000354 i i'

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F DETAILS 1.0 Persons Contacted W. Bacon, Principal Training Supervisor

• D. Beckwith, Licensing Engineer

• J. Clancy, Radiation Protection / Chemistry Manager

• E. Devoy, Technical Engineer, Nuclear Services Support R. Edmonds, Assistant Training Manager

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• R. Griffith, Station Quality Assurance Manager

• S. Funsten,. Maintenance Engineer

• M. Sesok, Site Representative Atlantic Electric Company

• J. Thompson, Technical Engineer, Controls

• C. Vonara, Operations Manager lJnited States Nuclear Regulatory Commission

• Meyer, Senior Resident Inspector

• Allsopp, Resident inspector

[ * Denotes those attending the exit meeting.

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The inspector also contacted other administrative and technical personnel during the inspectio .0 Hope Creek Generating Station (HCGS) ATWS Rule Implementation (10 CFR 50.62) (IP_25020)

2.1 Bac' _ nound Paragraph (c) of 10 CFR 50.62 specifies the ATWS mitigating system requirements for boiling water reactors (BWRs). Each BWR must have an alternate rod injection (ARI) system that is diverse (from the reactor trip system) from sensor output to final actuation devic ,

Each BWR must also have a standby liquid control system (SLCS) and equipment to trip the reactor coolant recirculating pumps (RPT)

automatically under conditions indicative of an ATWS. The ARI, SLCS, and the RPT must perform their functions in a reliable manne The Hope Creek Generating Station (HCGS) has a redundant reactivity control system (RRCS) to mitigate the potential consequences of an ATWS, The RRCS was part of the original design and construction of HCGS. A safety evaluation by NRC of the licensee's submittals for complying with the ATWS Rule was issued on October 14, 198 The evaluation concluded that the licensee was in compliance with the ATWS Rule. NRC Inspection Reports 88-10 (June 10,1989) and 88-27 (January 24,1989) verified compliance and closed out the SLCS and RPT part of the AWTS Rule. This inspection was to verified compli-ance of the ARI system with the ATWS Rule. The documents reviewed during the conduct of this inspection are listed in Attachment _ _ _ _ _ _ _ - _ _ _ - _ _ - - - _ - _ - _ - _

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2.2 Scope The ARI system was reviewed for compliance with the 10 CFR 50.62 ATWS Rule. Assessment included QA controls applied to the minor design change packages (MDCPs), operational adequacy, and reliability of the ARI syste .3 Alternate Rod Injection (ARI) System 2.3.1 System Description ARI is initiated by a signal from the RRCS automatic initiation functions or by manual RRCS initiation. The function of the ARI is to depressurize the scram valve pilot air header using valves different from the Reactor Protection System (RPS) scram valves, therein providing a redundant method for control rod injection. To assure protective action once the Class 1E ARI function is initiated, the function is sealed in by the solid state logic, and cannot be reset for 30 seconds. This action assures that the scram will go to completio Diversity from the reactor protection system (RPS) is achieved by the ARI system being installed in a different location with its own power feed and transmitters. Fail safe is achieved by energizing the trip modules while the RPS fails safe with modules that trip on loss of power. The ARI and RPS trip modules not only differ in their fail safe design but they are also made by different manufacturer Additionally, removal of portions of the ARI system for service will not result in protective actions because the system is normally deenergized. Bypasses for example, are not required for maintenance and test .3.2 Review for Compliance to the ATWS Rule The ARI system was installed and tested during the construction and start up of HCGS. The ARI system has been operating satis-factorily since the issuance of the operating license as evid-enced by reviewing the following:

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Four monthly and thr.e 18 month surveillanc On site and off site Safety Review Committees actions {

associated with the ARI syste The Incident Report Data Base, e.g., licensee event reports i (LERs) dealing with the ARI syste l

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Quality assurance (QA) audit and surveillance reports associated with the ARI syste _ _ _ _ - _ .

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The inspector's efforts concentrated on the. system modifications which had been mad Five minor design change packages (MDCPs)

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l-have been implemented since the initial operation of the ARI system. The inspector verified that Administrative procedure

" Station Design Changes, Tests and Experiments" (SA-AP.ZZ-008 (Q)), and System Engineering procedure " System Engineering .

Minor Change Process" (SE-AP.ZZ-008(Q)) were followed in the development, implementation, and close out of the MDCPs Each of the packages' included a Safety Evaluation (10 CFR 50.59), and a detail Design Inputs Workshee The MDCPs are:

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4-HM-0012, Add a CPU Reset Switch to Each RRCS Panel

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4-HM-0016, Replace 0-5 Volt Analog Input Isolators

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4-HM-0096, Upgrade RRCS Analog Trip Modules

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4-H0-0138, Improve Reliability of RRCS High Power Input and Output Isolator

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4-HM-0211, Upgrade RRCS Firmware Selected MDCP material procurement and receipt documentation were reviewed for items such as the key cap and resistor (P0 PI-22294b), Data Acquisition and Display Controller Card (DADC)

(P0 P1-261370), and switch (P0 PI-131922). The inspector found the documentation to be complete, current, and accessibl Equipment verified to be installed in accordance with the MDCPs, UFSAR, and vendor manuals include:

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A Central Processor Units (CPU) reset switch to eliminate the need to remove and restore power to RRCS panels (MDCP 4-HM-0012).

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Improved Analog Input Isolators in the RRCS to replace less accurate isolators (MDCP 4-HM-0016).

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Upgrade RRCS Analog Trip Modules (ATM) to eliminate false gross fail alarms (MDCP 4-HM-0096).

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Upgrade the Universal Logic Card (ULC) and the Data Acqui-  !

sition and Display Controller Card (DADC) (MDCP 4-HM-0211).

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ARI scram pilot valves IBFSV F160AC11 and BC11 as required by the UFSAR and GE Vendor Manual GEK-90357 ARI System Manual Initiation in the Cantrol Roo i

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No work was being performed on the ARI system during this-inspection. The inspector reviewed the following to verify

.the system had been properly contro11ed'to maintain compliance

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with the ATWS Rule:

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The inspector and an I&C technician walk' down of a monthly surveillance procedure (I-FT.SA-003(Q) for the Division 1 Channel C) was performed to verify procedure clarity and overall adequacy, as well the technician's understanding of the procedure. The' inspector also verified that procedures I-FT.SA-001(Q), 002(Q), and 004(Q) for the other three channels were identical. to the I-FT.SA-003(Q) surveillance procedur Data packages for three 18 month surveillance performed in

.accordance surveillance procedures IC-CC.SA-001(Q), IC-C SA-011(Q), and IC-SC.SA-008(Q).

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A search of the Incident Report Data Base produced LER 89-04. This LER described an inadvertent initiation of the ARI system due.to an inadequate I&C Troubleshootin Plan (Attachment 3 to procedure IC-GP-008(Q)). The inspector verified the specified corrective actions had been take Operations Department review and approval of the MDCP ' Review of operating procedure OP-SO.SA-001(Q), and emer-gency procedure OP-E0.ZZ-101(Q) for changes reflecting modifications which had been mad Lesson plan (LP) No. 302HC-000.00-024-04 for RRCS training I&C technicians that was conducted on December 15, 198 An exercise followed on the Nuclear Training Center RRCS Simulator.

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Nuclear Training Center records of selected individuals involved in the ARI system and MDCPs indicate that the individuals are trained and qualifie Review indicates that the ARI system activities were performed and documented in accordance with approved procedures by trained and qualified personne .4 QA/QC Interfaces l

The Inspector's discussion with QA personnel showed that no specific QA audits of the ARI system had been performed. A Surveillance Report (SR)89-171 verified a functional test had been conducted satisfactory-ily on the RRCS ATWS Recirculating Pump Trip. The inspector also ___-:_-=

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reviewed a Product Quality Certification (PQC) for the key pad and

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resistor requested in P0 PI-222945, and a change-in-order (CIO) of P0 PI-131922 requested for the central processor unit (CPU) switch. The SR, PQC, and the CIO were satisfactorily documented, accessible,.

complete and curren QA/QC coverage noted during the review of the.MDCPs; surveillance, and functional tests was adequately implemente .5 Conclusion The ARI system it in compliance with the 10 CFR 50.62 ATWS Rule and the licensee's commitments delineated in the SER. Compliance was implemented in accordance with approved procedures by trained and qualified personnel. The ARI system was verified to be operable by reviews of the changes affected by the MDCPs, walk down of surveillance and functional tests, review of.QA/QC coverage, and review of trainin .0 Management Meetings Licensee. management was informed of the scope and purpose of the inspec-tion at the entrance interview on June 26, 1989. The findings of the inspection were discussed with licensee representatives during the course of the inspection and presented to licensee management at the June 30, 1989 exit interview (see paragraph I for attendees).

At no time during the inspection was written material provided to the licensee by the inspector. The licensee did not indicate that proprietary information was involved within the scope of this inspectio l l

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ATTACHMENT A 2.1 Background 10 CFR 50.62, ATW3 Rule NRC letter of October 14, 1989, Compliance With ATWS Rule 10 CFR 50.62 (TAC No. 61255)

NRC Inspection Report No. 50-354/88-10 of June 10, 1988 1 NRC Inspection Report No. 50-354/88-27 of January 24, 1989 2.2 Scope 10 CFR 50.62, ATWS Rule 2.3.2 Review for Compliance to the ATWS Rule Administrative Procedure SA-AP.ZZ-008(Q), Station Design Changes, Tests and Experiments, Revision 11 System Engineering Procedure SE-AP.ZZ-008(Q), System Engineering Minor Change Process, Revision 3 10 CFR 50.59, Changes, Tests and Experiments UFSAR

. Vendor Manual GEK90357A, Redundant Reactivity Control System

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' Monthly Surveillance Procedure (SP) I-FT.SA-003(Q), Functional Test, RRCS, Division 1, Channel B SP I-FT.SA-001(Q), Functional Test, RRCS, Division 1, Channel A SP I-FT.SA-002(Q), Functional Test, RRCS, Division 2, Channel A SP I-FT.SA-004(Q), Functional Test, RRCS, Division 2, Channel 8 18 Month SP IC-CC.SA-001(Q), Channel Calibration, RRCS- Division 1, Channel A SP.IC-CC.SB-011(Q), Channel Calibration, RPS, Division 2 & 3 SP IC-SC.SA-008(Q), Sensor Calibration, Nuclear Boiler- Division 2 Operations Procedure (0P) OP-SO.SA-001(Q), RRCS Operations, Revision 1 L

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Emergency Procedure OP-E0.ZZ-101(Q), Reactor Pressure Vessel Control *

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Licensee. Event Report (LER) 89-04, ARI Initiation Due to Procedure Inadequacy in a Design Change Support Procedure l

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" IC-GP.ZZ-008(Q), Preclude ESF Actuations While Manipulating Instrument Isolation Valves, Revision .4 QA/QC Interface QA Surveillance Report 89-17- Functional Test of RRCS ATWS Recirculating

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Pump Test (5/25/89)

Purchase Order (P0) PI-131922, Central Processor Unit Switch, and Change-In-Order P0 PI-222945, Key Pad and Resistor , and Product Quality Certification

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