IR 05000387/1979008
| ML17207A237 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 03/29/1979 |
| From: | Mccabe E, Raymond W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17207A236 | List: |
| References | |
| 50-387-79-08, 50-387-79-8, NUDOCS 7906140207 | |
| Download: ML17207A237 (19) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I
7
. ~88.887 78-88 Docket No.
50-387 License No.
CPPR-101 Priority Category Licensee:
Penns lvania Power and Li ht Com an Two North Ninth Street Allentown, Pennsylvania Facility Name:
Susquehanna Steam Electric Station, Unit
Inspection at:
Berwick, Pennsylvania Inspection conducted:
February 27-March 2, 1979 Inspectors:
W. J.
Raymond, Reactor nspector date signed date signed re@~/
E.
C.
McCabe, Jr., Chief, Reactor Projects Section No. 2, ROSNS Branch date signed date signed Ins ection Summ'ar
Ins ection on Februar 27 - March 2, 1979 Re ort No. 50-387 79-08 8: I,,
I
I by
based inspector (31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br />).
Inspection areas (3):
implementation of preoperational testing administrative controls, including test organization, measuring and test equipment and test personnel training; followup on corrective actions taken in re-sponse to NRC:IE Bulletins and Circulars; and, followup on previous inspection items.
Results:
No items of noncompliance were identified.
Region I Form 12 (Rev. April 77)
V 9061. 40&a 7
DETAILS'ersons Contacted Penns lvania Power and'Li ht Com an
- Mr-.
- Mr.
- Mr.
- Mr.
Mr.
- Mr.
Mr.
- Mr.
- Mr.
- Mr.
Mr.
- Mr.
- Mr; R. Beckley, Acting RNQAE J. Bradford, Quality Supervisor R. Bryan, Supervisor of Maintenance R., Dunn, Superintendent of Plant J.. Edwards, Security Supervisor J. Everett, PP Quality - Engineer J.
Green, RNQAE D. Housenick, Mechanical Group Supervisor - ISG T; Oldenhage, Resident Engineer L. O'eil, Technical Supervisor R.. Prego, Project Engineer - NQA A. Sabol, Manager - NQA H.. VanEeden, Assistant ISG Supervisor Bechtel Power Cor oration
- Mr: G. Smith, ISG Supervisor U. S. Nuclear Re ulator Commission
- Mr., R. Gallo, Resident Inspector
denotes those present at the exit-interview on March 2, 1979 Status of Previous Ins ection Findin s (Closed)
Unresolved Item (387/77-12-05):
Supplemental response to IE Bulletin 77-01.
PPSL letter (PLA-183) to NRC:Region I dated June 29, 1977 stated that no pneumatic time delay relays are used on any safety-related systems for SSES.
Subsequent licensee reviews of installed equipment revealed that pneumatic time delay relays were installed in some safety-related applications.
The licensee was requested in NRC:Region I Inspection Report 77-12 to reevaluate this item and submit a supplemental bulletin response.
PP&L letter, PLA-225, dated March 3, 1978, provided updated information on the use of pneumatic time delay relays at SSES.
This item is further discussed in paragraph 4 of this report.
Submittal of the supplemental bulletin response is considered resolve..
Prep erational Test'Pro ram Licensee administrative controls of preoperational testing were reviewed to ascertain that controls are established in accordance with fSAR commitments and regulatory requirements..
Preoperational test organization, test personnel training and controls of test and measurements equipment were audited during this inspection.
Test Or anization (1)
Discussion PP&L has overall responsibility for all activities during the preoperational test program, as defined in the Startup Administrative Manual, Procedure AD 2.1.
Procedure AD 2.1 establishes the Integrated Startup Group (ISG),
composed of PPSL, Bechtel, GE and other personnel as needed, to control all testing activities.
The ISG is directed by a team composed of the ISG Supervisor. and the Assistant ISG Supervisor, whose function is to coordinate jobsite startup activities and provide technical direction to plant groups participating in the startup.,
The test organization and controls defined by procedure AD 2.1 were reviewed to verify that the following specific items are formally established by the administrative procedures:
(a)
qualifications of key test program personnel are formally specified in accordance with FSAR commitments (b)
responsibilities of key test program personnel (c)
method and responsibility of appointing 'test personnel to assure minimum qualification requirements are met (d)
organizational lines of authority and responsibility are established (e)
interfaces between various groups involved in the test program are established and responsibilities are clearly defined
Startup Administrative Controls include the establishment
'f'
Test'eview Board (TRB) which, together with the PORC', will provide review and approval of Initial Startup Test-procedures and test results.
The licensee's test organization was found to be consistent with FSAR and regulatory commitments and, except as identified below, the inspector had no further comments in this area.
(2)
References (a)
PP&L Startup Administrative Manual (b)
AD 1.1, Introduction to Startup Administrative Manual, Revision 1, January 15, 1979 (c)
AD 2.1, Startup Organization and Responsibilities, Revision 0, May 8, 1978 (d)
AD 2'.2, Bechtel/PP&L Activity Interface, Revision 0, March 27,. 1978 (e)
FSAR Section 14.2.2 (f)
PP&L Response to FSAR guestion 423.1 (3)
~Findin s
(a)
The ISG organizational structure defined in FSAR Figure 14.2-1 is established by AD 2. 1 and defined in Figure 1 of AD 2.1.
However, AD 2.1 establishes an additional functional group entitled Staff Special-ists, which has no in line responsibilities and reports to 'the ISG Supervisory Team.
Section 4.8 of AD 2.1 defines the group responsibilities, which are to perform staff functions and report to the Assistant ISG Supervisor, who has the option of assigning group personnel to a System Startup Group as required to make optimum use of technical expertis The inspector stated that licensee changes to the organizational structure which do not alter lines of authority and responsibility are acceptable without prior NRC'eview.
In general though, the FSAR should reflect, the licensee's established organization and an update of Figure 14.2-1 on a subsequent FSAR revision would be appropriate.
The inspector stated further that for changes, to Initial Test Program, Station Operating and/or Corporate organizations which do alter lines of authority or defined func-tions, the licensee's NRR project management should be, notified of the details of the change prior to implementation.
The implementation of such a change after OL issuance should also be accompanied by a change to the appropriate sections of the Facility Technical Specifications.
The licensee acknowledged the inspector's comments.
and stated that differences between the FSAR and the Startup Administrative Manual would be resolved.
The inspector had no further comment on this item.
The. inspector noted that the Startup Administrative Manual does not specify the minimum qualification requirements for TRB members or test program personnel, as defined by FSAR 14.2 and guestion 423.1, nor is the method. and responsibility for appointing personnel to key test program positions clearly defined.
AD 2..1 does specify that the ISG Supervisor is responsible to provide overall direction, guidance and support to ISG personnel and to advise on manpower/personnel requirements.
Discussions with the licensee indicated that the ISG Supervisor and Assistant Supervisor have responsibility for appointing personnel to the test organization, in accordance with PP&L guidelines defined outside the scope of startup administrative control, and for assuring that ISG positions are staffed by personnel who meet the minimum required qualifications.
The inspector noted through a sampling review of resumes, experience histories and training records of personnel assigned to the ISG that test personnel qualifications are in conformance with the FSAR requirement The licensee stated that minimum qualification requirements would be incorporated in the Startup Administative Manual either directly or by reference to the FSAR and that the ISG Supervisory responsibility for appointing personnel to ISG positions would be clarified.
Completion of licensee actions in this area will be reviewed on a subsequent inspection (50-387/79-08-01).
(c)
The inspector noted that staffing of ISG positions is incomplete at this time, particularly in the LSTG Startup area.
Mechanical, Nuclear, Electrical and IKC System Startup Groups are adequately staffed.
The ISG Supervisor stated that preoperational testing of the, 125 YDC system should start within the next two months and that complete staffing of ISG positions is in progress.
The inspector had no further questions in this area at the present.
ISG staffing will be further examined on subsequent inspections.
b.
Test Personnel Trainin (1)
Discussion Test personnel training requirements have been established in the Startup Administrative Manual and responsibilities have been assigned to assure training requirements are completed.
The individual System Group Leaders are responsible for assuring training requirements are satisfied by test personnel in their respective system startup groups.
The ISG Supervisory Team has overall responsibility for assuring completion of required training.
Required training includes (but is not limited to):
general orientation, including the PP&L system, ISG organization and responsibilities, the Initial Test Program, prints/
drawings/indices, SSES gA training, radiation safety and security; power plant training, including PSIDs, safety tagging, ISC, operations, maintenance and chemistry procedures, and storeroom; BHR technology, including BWR systems, nuclear engineering, power tests, and specific component testing; and, ISG training, including FSAR 14.2, the Startup Administrative Manual, gA Manual and
Program, the Startup Technical Hanual, selected parts of 10 CFR, and selected regulatory guides and ANSI standards.
The. inspector verified through a review of System Startup Group Traing records, that test personnel training specifi-cally included testing administrative controls, technical objectives of'ystem tests and gA/gC for testing.
The inspector further verified that training requirements have been implemented for personnel involved in the following test program areas:
(a)
test'rocedure preparation (b)
test'rocedure approval (c)
test performance and documentation (d)
test result review, and approval
, Except as noted below, the inspector had no further comments in this area.
(2)
References (a)
AD 10.1, Startup Indoctrination and Training, Revision 0, July 26, 1978 (b)
AD 10.2, Startup guality Program, Revision 0, July 26, 1978 (c)
AD 7.1, Preoperational Test Program, Revision 0,
'ebruary 3,
1978 (d)
AD 7.2, Startup Technical Procedure Format and Content, Revision 1, July 3, 1978 (e)'D 7.3, Startup Technical Manual Document Control, Revision 1, July 3, 1978 (f)
AD 7.4; Startup Technical Procedure Implementation, Revision 3, January 30, 1979
c ~
(g)
AD 7.5, Preoperational/Acceptance Test Procedure Format and Content, Revision 2, October 12,. 1978 (h)
AD 7.6, Preoperation/Acceptance Test Procedure Control, Revision 1, July 26, 1978 (i)
AD 7.7, Preoperational/Acceptance Test Procedure Implementation, Revision 0, January 23, 1978 (3)
~Findin s
(a)
Based on a sampling review of System Startup Group training records, the administrative training require-ments of test directors and startup engineers is es-sentially complete.
There are, however, recently assigned members of the test staff who have not completed the required administrative manual training.
The licensee was cognizant of this situation and stated that required training would be completed prior to active involvement in preoperational testing.
The inspector had no further questions on this item at this time but, this area will be further reviewed on subsequent inspections (50-387/ 79-08-02).
Test and Measurement E ui ment (1)
Discussion Administrative procedures and controls have been established in the Administrative Procedures Manual and the Startup Administrative Manual for special test equipment to be used during the preoperational test program.
The inspector verified that established procedural controls included the following:
(a)
a listing of controlled test equipment, including specific calibration requirements and the calibration history (b)
controls for storage and issuance of test equipment to preclude use of equipment that has not been cali-brated within the. prescribed interval
(c)
controls for identification of which equipment is used with the individual test procedures to allow subsequent evaluation and/or retest if test equipment is. found out of calibration The plant: ISC staff has-overall'esponsibility for the
'pkeep and maintenance of measuring and test equipment (MTE).
The ISG is responsible for preparation and review of out* of calibration reports, checkout and control of test. equipment as required for testing and assuring MTE required for testing is added to the controlled test equipment. inventory.
Except as noted below, the inspector had no further comments in this area.
(2)
References (a)
AD 6;9, Test Equipment Control, Revision 0, April 7, 1978 (b)
PPIEL. guality Assurance Manual, Procedure 13.0, Control of Measuring and Test Equipment, Revision 0, Jul'y 20, 1978 (c)
Administrative Procedures Manual Procedure AD-00--
040, Control and Calibration of Plant Measuring and Test. Equipment, Revision 0,- January 5,
1979 (d)
Calibration History Form AD-00-040-2A (e)'tandard Usage Log AD-00-040-5 (3)
~Findin s
The inspector noted that the plant I8C group is in the process of setting up the MTE program to support preopera-tional testing and that additional work is required in this area to support testing.
This area will be further examined on subsequent inspection.
IE Bulletin and Circular Followu a 0 Discussion IE: Bulletin and Circulars issued to PPSL were reviewed to verify the following:
(1),
bulletins and circulars received by PPIIL corporate manage-ment were forwarded to appropriate individuals within the organization, including station management, for information, review and/or corrective actions as required (2)
PPSL bulletin responses were submitted to the NRC within the specified time period (3)
licensee reviews and evaluations of bulletins and circulars are complete and accurate, as supported by other facility records and by inspector observations of installed plant equipment.
Inspector observations of installed equipment were made. in conjunction with inspection tours of the facility during the period of February 28 - March 1, 1979 and covered the following areas/panels:
diesel generator C8D local control panels; panel 1D254-A27/El 670; panels 1C694, 1C661, 1C609 - A12/El 729, and, panel 1C617-A12/of El 754.
(4)
corrective actions specified in licensee bulletin responses or internal circular evaluation memoranda have been com-pleted and/or responsibilities have been assigned to specific individuals for completion b.
~Scc e
The bulletins and circulars reviewed during this inspection are listed below, together with applicable references.
(1)
IEB 77-01, Pneumatic Time Dela Rela Set oint Drift; Ref: PLA-225, dated March 3, 1978; PLA-183, dated June 29, 1977; GE letter GB-123, dated May 11, 1978
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(>>)
(12)
IEB 77-08,'Safe uards Durinq an Emer enc
- Lockin
~S stems; Ref:
PLA-216, dated February 6, 1978; PPSL Physical Security Plan for SSES, inclusive of Change B,
dated February 15, 1979 IEB 78-01, GE CR120A Rela Flammable Contact Arm Retainers; Ref:
PLA-247, ated April 27, 1978; GB-123, dated May 11, 1978 IEB 78-03, BWR Off as Ex losive Gas Mixtures; Ref:
PLI-3032,, dated May 2, 1978 IEB 78-04, Environmental uglification of SMLS Inside Con tainment; Ref:
PLA-250,
~
dateda Nay 8, 1978 IEB 78-05, Malfunction of Circuit Breaker Auxiliar Contact Mechanssims'in GE Model'CR105X; Ref:.
PLA-260, date June 2, 1978; PLA-266, dated July 3, 1978 IEB 78-06, Defective Cutler Hammer T
e M Rela s with DC'Coils; Ref:
PLA-268, dated July 18, 1978; PLA-292, dateda September 28, 1978 IEB 78-10, Ber en-Patterson H draulic Shock Su ressors; Ref: PLA-279, ated August 14, 978 IEB 78-14, Deterioration of BUNA-N Com onents in ASCO Solenoids; Ref:
GE SIL 128, Revision 1, ated January, 1976; PPDI-2.4, Open Items Program, Revision 0, June 20, 1978 IEC 78-02, Lubricatin Oils for Terr Turbines; Ref:
PDN-78-170, dated May 23, 1978; internal memo to Manager, NgA, dated May 23, 1978 IEC 78-03, Packin Greater Than T e
A uantities of LSA Material; Ref:
PDN-78-192, dated May 31, 1978 IEC 78-04, Installation Errors that Could Prevent Closin-Fire Doors; Ref:
BLD 9489, dated July ll, 1978; PLI-3662, dated September 12, 1978
(13)
(14)
IEC 78-07, Ber en-Patterson Series 25000 H draulic Test Stand; Ref:
PLI-3255, dated June
'12, 1978 IEC 78-09, Arcin of GE Nema Size 2 Contactors; Ref:
BLP-9938, dated October 27, 1978 c.
~Findin s
Bulletins 77-08, 78-03, 78-06, 78-10 and 78-14 and Circulars 78-02, 78-03, 78-04, 78-07 and 78-09 have been satis-factorily dispositioned by the licensee and, except as noted below, the inspector had no further comments on them.'2)
(3)
The inspector noted that the licensee's response to IEB 78-04 was submitted to the NRC on May 8, 1978, which is one month later than the submittal date. specified in the bulletin.
This late submittal appears to be an isolated case.
The licensee acknowledged the inspector's comments and stated that attention would be given to this area to assure timely submittal in the future.
IEB 77-01 Documented licensee reviews, including input from GE, Bechtel and NSSS subvendors, indicate that no ITE relays of the type specified in the bulletin or relays with repeat accuracy greater than
+ 15% are used in safety-related applications at SSES.
The licensee's response did not specify the range of repeat accuracy of installed time delay relays nor did it address PPSL basis for acceptance of existing relays as requested by IEB 77-01.
Discussions with licensee personel during a telephone conversation on March 9, 1979, indicated that time delay relays in use at SSES were selected under design specifications requiring a repeat accuracy, in general, less than
+ 155; further, PPSL acceptance of the relays would be based on cer tificates of compliance supplied by the relay vendor.
The licensee stated that further detailed information would be available for NRC:Region I review by May 1, 1979.
e This item is unresolved pending subsequent review of the licensee's action in this area (387/79-08-03).
(4)
IEB'77-08 The licensee's response dated February 6, 1978
~PLA-216 stated that, based on the draft SES Security and Emergency Plans, the design of the SSES facility is in. conformance with the requirements of IEB 77-08.
The Emergency and Security Plans were subsequently submitted to the NRC.
Inspector review of the Security Plan confirmed
, that the IEB 77-08 concerns are addressed.
The Emergency and Security Plan-detailed implementing procedures, which are presently being prepared, will also address the bul'letin items.
Discussions with the Security Supervisor indicate that the Security implementing procedures will be completed by September, 1979.
An entry has been made
'n the PPSL Open Item Tracking System (PPDI-2.4), assigning
'esponsibility to the Security Section for completion of the required actions.
The. inspector had no further comments on this item at the present.
Further review of this item will be incorporated in-NRC:Region I review of SSES implementation of the physical security plan on subsequent inspections (387/79-08-04).
(5)
(6)
IEB 78-01 Documented licensee reviews, including input from GE, Bechtel and NSSS subvendors, indicate that no CR120A relays are used in safety-related equipment supplied for SSES.
However, discussions with licensee representatives in a telephone conversation on March 9, 1979 indicated that the results of the reviews conducted in regard to the subvendors (GB-123)
have not been formally received by PP8L, but are forthcoming.
The inspector stated that this item is unresolved pending subsequent review of the PP8L disposition and acceptance-of the subvendor review (387/79-08-05).
'IEB 78-04 The licensee's response to this bulletin indicated that none of the subject stem mounted limit switches
'(SMLS),
NAMCO Model D2400X or. EA-170-302 SNAP LOCK, are used in SSES safety-related design functions.
The response indicated that the A/E uses similar type switches for indication lights only and not for protective logic functions.
Information from the NSSS vendor indicated that the subject switches were not employed inside the
(7)
Fur ther information was not availab'le onsite at the time of this inspection regarding (i)
details of the A/Es use of SMLS for indication light applications;.
and (ii) whether SNLS are employed on safety-related systems outside of primary containment which could be subjected to adverse environmental conditions during accident sequences.
The inspector discussed with licensee personn'el the following NRC Staff Position in regard to environmental qualification:
(i) SHLSs (or the equivalent)
used to provide. valve position indication in the control room (typically on containment isolation valves or ESF valves used for long term shutdown) to allow the control room operator to follow accident progression and/or verify automatic ESF equipment operation, must be qualified for the environment; and (ii) NRC Staff Reviews conducted to date. have requested specific, detailed documentation of safety-related electrical equipment. environment qualifi-.
cation on such item as:
environmental parameters that plant equipment may be subjected to. during an accident; and, qualification test methods, test conditions and test results.
PPSL should assure that detailed qualification documentation is complete'nd expect detailed Staff examination of same.
The licensee acknowledged the
.
inspector's remarks.
The inspector noted that environmental qualification of electrical components is presently under review between PPSL and NRC:NRR.
This item will be further reviewed by-NRC:RI pending completion of NRR review of the licensee's qualification program and in conjunction with other electrical equipment environmental qualification inspections(387/79-08-06).
IEB 78-05 Documented licensee reviews of this item indicate that no GE105X auxiliary contact mechanisms are employed in safety-related applications at SSES.
Information from the NSSS vendor indicated non-vital use of the mechanisms in the RPS, as follows: (i) annunciation and indication, (ii) signals to the plant computer; (iii) spare contacts; and (iv) backup scram solenoids.
In regard to item (iv),
the application in backup scram solenoids is considered nonessential since the solenoids provide a backup scram function,. for which no credit was taken in the accident analysis:
The licensee.'s response stated that corrective actions would be taken as required in accordance with GE instruc-tions, provided as an enclosure to IEB 78-05.
Further information. was not available during this inspection.
regarding the specific corrective actions that will be taken,. along with the mechanism for accomplishing the action.
A licensee representative stated in a telephone conversation with the inspector on March 9; and 20, 1979 that further information will be available for review by April 15, 1979.
The, inspector also requested additional information on the procedures established by PPSL to assure that such items are precluded from use in safety-related. systems.
This. area will be further reviewed on a subsequent-inspection (387/79-08-07).
(8)
IEB 78-14 The licensee's response indicated that NSSS vendor recommendations contained in SIL 128, Revision
and supplemental, would be implemented in the periodic maintenance program.
The inspector verified through discussions with licensee personnel that responsibil'ity for-completion of the corrective actions has been assigned and the, item is being tracked on the OITS, Sequence No.
133, with a target completion dated of May 1, 1980.
The inspector noted that vendor recommendations of SIL 90 for the scram discharge volume have also been incorporated into the OITS.
The inspector had no further questions regarding this item.
5.
Unresolved Items Unresolved items are those items for which further information is required to ascertain whether the items are acceptable or items of noncompliance.
Unresolved items are discussed in paragraph 4 of this repor.,
Exit Interview A management meeting was held with licensee personnel (denoted'. in paragraph 1) at the conclusion of the inspection on March 2, 1979.
The purpose, scope and findings of this inspection were discussed as they appear in the details of this repor e ')
I gJ 0