IR 05000387/1981013
| ML17139A383 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 07/23/1981 |
| From: | Caphton D, Mccabe E, Rhoads G, Troskoski W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17139A382 | List: |
| References | |
| 50-387-81-13, NUDOCS 8108100227 | |
| Download: ML17139A383 (26) | |
Text
4 Report No.
, Docket No.
U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I
,License No.
Licensee:
Priority d
Category le to enn
'a 18101 Facility Name:
Sus uehanna Steam Electric Station Inspection at:
Salem Township, pennsylvania Inspection conducted:
June 22 - July 22, 1981 q, e. L c~. 3>
G Ci.
Rh ads es'dent Ins ctor Inspectors:
a t nspector C
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Ca n, Chief, Test Programs Section DETI Approved by:
M f'
Ebe C.
McCabe, Chief, Reactor Projects Section No. 2B, DRPI
~ n(W date signed
g F d te igned 7 e8" date igned
~ ln/s date signed Ins ection Summar:
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J Iy 22, 1981 (2 0 t II
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50-381/81-133 Are'as Ins ected:
Routine inspection by the resident inspector and region-based inspectors of': Preoperational test witnessing; preoperational test program imple-mentation; preoperational test review; technical specification review, operating staff training; and Bulletin and Circular followup.
The inspectors also performed plant tours and reviewed licensee actions on previously identified items.
The inspection involved 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> by the regional inspectors and72hours by the resident inspector during both regular and backshift periods.
Results:
No items of noncompliance were identified.
Region I Form 12 (Rev. April 77)
8108100227 810724 I
i r DR ADOCX 0S000S87,I
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DETAILS 1.
Persons Contacted Penns lvania Power and Li ht Com an L. Adams, Plant Supervisor of Operations T. Clymer, Site gAE F. Eisenhuth, Senior Compliance Engineer E. Gorski, Plant guality Supervisor J.
Green, Operations guality Assurance Supervisor H. Keiser, Superintendent of Plant S.
Shah, ISG Test Engineer R. Stanley, ISG Test Engineer D. Thompson, Assistant Superintendent of Plant G. Yezefski, ISG Test Engineer Bechtel Cor oration J. Barbour, ISG Test Engineer E. Figard, ISG Supervisor C. Jaffee, ISG gC Engineer M. Johnson, ISG QC Engineer K. Stout,"', Project Field guality Control Engineer General Electric Com an D. Turner, GE Operations Site Manager The inspectors also interviewed other PPSL employees, as well as employees of Bechtel and General Electric Company.
2.
Licensee Action on NRC Findin s:
a.
Closed Unresolved Item 387/81-02-07 Diesel Fire Pum Surveillance
~esti n On January 19, 1981 the inspector had reviewed Maintenance Procedure S0055, the lleekly Surveillance Procedure for testing,,-the diesel fire pump.
The inspector noted that the procedure allowed operators to adjust the diesel engine throttle valve during the test.
The inspector noted that this procedure and apparent lack of operator training on the diesel engine driven fire pump had resulted in the throttle valve being left in a position which did not allow the fire pump to satisfy maximum fire protection system flow and pressure demands.
On July 16, 1981 the inspector reviewed the Shift Supervision required reading book and noted that a revised S0055 had been placed in the required reading book.
The entry included a note insuring that the operators were aware that the procedure had been changed and that the position of the throttle valve was not supposed to be changed during the pepfopppnce of
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this test.
The inspector also Ieviewed Haintenance Procedure S0055, and noted that the procedure no longer included steps for changing the the throttle valve position.
This item is considered closed.
Closed) Unresolved'tem'87/81-'02-'3
'Diesel'Generator Testin
.
On January 19, 1981 the inspect'or witnessed the'nitial component test run of the "B" Diesel Generator.
The inspector no'ted that a temporary diesel cylinder temperature monitoring system had been instal,l,ed to pro-vide operator information locally.. 'A',review of Temporary Operuating Procedure OP-24-001, Revision 0, Draft, indicated that no maximum cylinder temperature had'een specified.
On July 1, 1981 the inspector reviewed a memorandum from PP&L Senior Licensing Compliance Engineer, dated April.30, 1981 which stated that Cooper Energy Services, the diesel generator vendor, had been contacted and stated that maximum cylinder operating temperature was 1150o F. for the diesel installed at Susquehanna Steam Electric Station.
On July 16, 1981 the inspector reviewed Temporary Operating Procedure OP,-
24-001, Revision 0, Draft, and noted it had been changed on April 29,; j981 -"
to include the maximum cylinder operating temperature in Sections 3. 1;8.3 and 3.2.B.3.
This item is considered, closed.
3, 'Plant'Tour The inspector conducted periodic tours of accessible areas in the plant during normal and backshift hours. 'uring these tours, the following items were eyaluated:
Hot Work: Adequacy of fire prevention/protection measures used.
Fire Equipment: Operability and evidence of periodic inspection of fire suppression equipment.
Housekeeping:
Minimal accumulations of debris and maintenance of required cleanliness levels of'ystems under or'following testing.
Equipment Preservation:
gaintenance or special precautionary measures f'r installed equipment, as appli,cable.
Component Tagging:
Implementation and observance of equipment tagging for safety, equipment protections and jurisdiction.
Instrumentation:
Adequate protection for installed instrumentation.
Logs:
Completeness of logs maintained.
Security:
Adequate site construction securit H I
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Cable Installation:
Adequate precautions taken to prevent damage to in-stalledd cables.
Communications:
Adequate public address system.
Equipment Maintenance and Controls: Corrective maintenance is performed in accordance with approved procedures, no unauthorized work activities on systems or equipment, no uncontrolled openings in previously cleaned or flushed systems or components.
No unacceptable itemsieere ident1fied-.,
4.
IE Bulletin and Circular Followu a.
Discussion IE Bulletins and Circulars iissued to PP8L were reviewed to verify the following:
(1)
Bulletins and circulars received by PP8L corporate management were forwarded to appropriate individuals within the organization, in-,i eluding station management, for information, review and/or corrective actions as required.
(2)
PP8L 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.
(4)
Corrective actions specified in licensee bulletin responses or internal circular evaluation memoranda have been completed and/or responsibilities have been assigned for,completion.
b:
~Findin s
(1)
The inspector reviewed licensee actions relative to IE Bulletin'80-01,
"Operability of ADS Valve Pneumatic Supply."
The inspector reviewed the following relative to this bulletin:
PP8L letter to the NRC, PLA-652, dated March 16, 1981, Response to IE Bulletin 80-01.
PP8L letter to the NRC, PLA-659, dated March 16, 1981, Susquehanna Steam Electric Station Updated Response to TMI Related Requirements.
The inspector noted that Action Item 2 of the bulletin requested licensees to determine if periodic leak tests were being performed on ADS accumulator systems to assure emergency pneumatic supply for the FSAR-required number
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4, and duration of valve operations, PP8L's lettel to the NRC, I'L$-652, stated this action item was not applicable to Susquehanna, Steam Electric Station, and that PP8L would respond to the TMI Action Plan<gequirement II.K.3.28 concerning accumulator leakage.
The inspector then reyiewed PP8L's response to TMI Related Requirements, PLA-659,Section X. 1.60 which discusses the requirements for qualification verification oi'ccumu-lators on ADS valves.
The licensee responded to this requirement by stating that they would review the BHR Owner's Group Generic Eyaluatlon and then respond to this item, On June 29, 1981 the inspector discussed this action item with the PP8L Senior Results Engineer who stated the licensee was not intending to per-form periodic leak tests on this system since it ~Ias not a technical specification requirement.
On July 13, 1981 the inspector told the Superintendent of Plant that this item will remain open pending a review of the need to p'erform leak rate testing of the instrument air system.
(2)
The inspector reviewed licensee actions relative to IE'Bulletin'80-'3,
"Cracking in Core Spray Spargers."
The inspector reviewed the following relative to this bulletin:
PP8L response to IE Bulletin 80-13, PLA-712, dated April 20, f981.
PP8L response to generic letter 81-01 and NUREG 0313, PLA-856, dated June 30, 1981.
The inspector noted that the licensee had stated that the augmented inspec-tion requirement of IE Bulletin 80-13 should not be performed on the Core Spray Spargers since Type 304L stainless steel had been used to fabricate the Core Spray Spargers.
In the licensee'sresponse to NUREG 0313, the licensee again stated that a carbon-limited type of 304 stainless steel had been used and that intergranular stress cracking corrosion should not be a problem with this system.
This letter was sent to the Division of Licensing, Nuclear Reactor Regulation (NRR) for their review.
This Bulletin will remain open pending review of NRR'sacceptance of this position.
(3)
The inspector reviewed licensee actions relative to IE Bulletin 81-03,
"uyi gi kg ft if gilt 'ftygyt C
~y CORBICULA SP. (Asiatic Clam) and MYTILUS SP. (Muscel)."
The inspector reviewed the licensee's response to the NRC for this bulletin, PLA-843, dated June 17, 1981.
Based on the review of this letter the inspector Cconcluded. that the licensee does 'not have either species of mo),1'usk present near Susquehanna Steam Electric Station, and they do have an Aquatic Monitoring Program in effect which is capable ofy detecting the presence of these imoilusks if they shouidg
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This bulletin is considered closed, 5.
Prep erational Test Pro ram'Im'lementation
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Inte rated Startu Grou '(ISG) Trainin (The inspector held discussions with the Integrated Startup Group (.ISG)
Supervisor about the preoperational test program and test organization; included in the discussion were qualification and training requirements for test directors of both PP&L and various contractor organizations.
The inspector noted that licensee commitments concerning these requirements are found in the following documents:
FSAR Chapter 17, Answer to guestion 423. 1.
FSAR Chapter 17, Answer to guestion 423.24.
The inspector requested that the licensee representative provide adequate documentation to show that all preoperational test directors meet the minimum qualification requirements specified at the time of assignment to that function and that they have received the necessary indoctrination/
training in nuclear power plant systems and component operation in a nuclear power plant that is substantially similar in design.
The records that are available on site were not sufficient to demonstrate compliance with the above commitments for contractor personnel.
The licensee representative acknowledged the concerns and informed the inspector that the personnel records for all test personnel on site were being brought up to date.
It was estimated that this would be completed in 3-4 weeksqpending review of these qualification/training records before the majority of preoperational testing takes place.
This item is considered unresolved pending NRC review of the training records.
(387/81-13-01)
b.
Test Program Administration The inspector interviewed two preoperational test directors to determine how the test program was being administered.
Included in these discussions were:
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Jurisdictional controls observed for system turnover; Methods for verifying that a test procedure is current prior to its Use; Methods to change a procedure during the conduct of a test;
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criteria for interruption of a test and continuatlon of pn interrupted test; and Methods for identifying deficiencies, docugentinq their resolu-tions and retesting.
After the discussions were held, the inspector toured the respective systems (Emergency Diesel Generators and Control Rod Driye Systems)
with the cognizant test direc'tor to spot check tagouts, and verjfy that system
,boundary,isolations..and other jurisdictional controls were, being emjlqjed in the field.
No items of noncompliance were identified.
c.
Test and'Measurement E ui ment The inspector reviewed Procedure AD-00-040, Control and Calibration of Plant Measuring and Test Equipment (M8TE), Revision 1, and held discussions with the Assistant I8C Foreman in charge of the calibration lab to Verify that administrative controls have been implemented to assure that measuring and test equipment used in activities affecting quality are properly controlled, calibrated and adjusted at specified periods to maintain accuracy;,
within necessary limits.
Calibration records of seyergl instruments were checked on a sampling basis to verify adherence to 'the".established adminis-trative controls.
No items of noncompliance~)were identified.
- d.
Com onent Re lacement (I)
References (a) Startup Administrative Manual Procedure AD 6.4, Revision 8,
"Startup Work Authorization."
(b) Startup Administrative Manual Procedure AD 6.6, Revision 5,
"'tartup.Work Request."
(c)
PP8L guality Assurance Manual Procedure, SP-ll, Revision 5,
"Control of Nonconformances."
(d) Plant Administrative Procedure AD-00-046, Revision 2, "Work Authorization System."
(e) Bechtel Field Procedure FP-G-25, Revision 1, "Field Procedure for Controlling Equipment Substitutions for Susquehanna Steam Electric Station, Units 1 and 2."
(2)
Ins ector Findin s
The inspector reviewed the above references and the following Equipment Substitution Records (ESR) to ascertain whether proper controls were being maintained for equipment taken out of Unit 2 and placed in Unit 1 as replacements for defective components;
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(a)
ESR 1011 (b)
ESR 1012'c)
ESR 1014 (d)
ESR 1015 (e)
ESR 1022 (h)
ESR 2523 For all the above ESRs.the'nspector'-=verified that the-defective component had been the subject of a nonconformance Report or Work Authorization as described in reference (c), and that work performed was done in accordance with references (a), (b) and (c).
No unaccept-able items were identified.
The inspector also reviewed ESR logs to verify that the Bechtel guality Control Organization (gC)
had received copies of all quality related ESR's prior to equipment substitution as described by reference (c).
The inspector could find no record of Bechtel gC receiving the following ESR's:
(1)
1007 (2)
1013 (3)
1014 (4)
1022 (5)
1025 The inspector stated that there does not appear to be enough controls on the system to assure that gC is receiving the quality related ESR's as prescribed by reference (e).
The inspector was shown Bechtel Project Field Audit 24-3-7, guality Assurance Finding (OAF) Number 3, dated February
to March 23, 1981 which also describes this type of deficiency in the control of ESR's.
The inspector told the Licensee Construction Manager on July 17, 1981 that this item will be unresolved pending dispositioning of the audit finding and review of subsequent licensee actions.
(387/81-13-02)
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6.
Preo erational Test Witnessin a.
Diesel Generator
"D" Testin On July '6,$~1981 the inspector witnessed the performance of Section 10.3. 11. 1, "Overspeed Trip Test of "D" Diesel Generator of Preoperational Test" P24. 1, Revision 1, approved April 29, 1981.
The inspector reviewed Sections 10.2 of the test which verified initial system lineup to support running the "D" Diesel Generator.
The inspector noted that step 10.2. 1.2i (5) had not been signed off and a Test Change Notice (TCN) Number 003 had been written affecting this step.
The step was a verification that electrical panel 1D644 (Unit 1) and 2D644 (Unit')
were energized with 125VDC power.
The TCN stated that Unit 2 was still under construction, the Unit 2 power had not been turned over to the Inte-grated Startup Group (ISG), and therefore power to the Unit 2 BUS 2D644 was not verified.
Neither the TCN nor the test step 10.2. 1.2 (5) indicated 1D644 had been verified energized.
When questioned the Test Director stated this panel had been verified energized, and added a step to the TCN which added a verification statement for assuring 1D644 was energized, The first attempt to perform Section 10.3. 11 to overspeed test the "D" Diesel Generator, was aborted when it was discovered the procedure did not remove the diesel governor from service.
This prevented the diesel from reaching its overspeed trip setpoint.
A Test Change Notice Number 032 was written and approved to bypass the governor.
Section 10.3. 11. 1 was then reperformed with the diesel generator tripping at 663 revolutions per minute (RPM).
The procedure stated the nominal setpoint would be 660 RPM with a 'maximum trip setpoint of 675 RPM.
The inspector noted that the TCN written for the governor did not include steps for readjusting the governor to its(origjnjl setpoin~tjnd.,'testing the.,goyej'nay topsgupe'he adjustment was correct.
The inspector questioned the Test Director,"
who stated the TCN would be changed to include these steps.
The inspector had no further questions.
7.
Containme'nt Isolation Valves a.
References (1)
FSAR Table 6.2-12.
(2)
PPSL letter to NRC, PLA-659, dated March 16, 1981, Updated Response to TMI Related Requirement I
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Ins ector Findin s The inspector reviewed reference (~j.) and ~Table X 1.29-1 of reference (2) to determine the containment isolation valves for penetration,X 204A', X 205A, X 204B and X 205B.
These penetrations are for the suppression pool spray rings and the suppres-sion pool cooling modes~ of RHR.
The inspector noted that reference (1) stated that the containment isolation valves for these penetrations were E-11-HV1F028A (B) and E-11-HV1F011A (B) and that the valves would close on certain containment isolation signals.
Table 'X. 1.29-1:o'f reference (2) stated that the containment isolation valves for these penetrations were as follows: (1) For the A loops: E-11-HV1F028A E-11-HV1F024A (2) For the B loops: E-11-HV1F027B E-11-HVlF024B The inspector then reviewed (the licensee's Draft Technical Specification Submittal of October 1980.
In the October 1980 submittal, Table 3.6.3-1 lists primary containment isolation valves.
The table lists the following valves as automatic isolation valves: E-11-HV1F024A, B E-11-HV1F027A, B E-11-HV1F028A, B There is a note for the 1F027A,B, and 1F024A, B valves which states that the valves perform a containment isolation function, however, they aye not leik tested, and no credit is taken for the valyes.
The Ell-HV-lF011A, B valve is listed on Table 3.6.3-1 as a Manual Isolation Valve.
The inspector next reviewed Table 36.3-1 in the most recent draft of the Proof and Review Copy of the Proposed Technical Specifications which con-tinues to list Ell-HVlF011A,B as manual isolation valves and also lists Ell-HV-lF024A,B; Ell-HV-lF027A,B; and E11-HV-1F028A,B as automatic isola-tion valves, but there is no note with the 1F027A,B and 1F024A,B (valves, talking about leak tests, or not taking credit for the valves.
The inspector discussed these discrepancies with the Superintendent of Plant on July 13, 1981.
On July 16, 1981 the Senior Compliance Engineer discussed this item with the inspector, and stated that the containment isolation valves for pene-trations X 204A,B, and X 205 A,B are"','Ell-HV-1F011A,B and E-11-HV-1F028A,B,
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that both sets of valves will close on a containment isolation signal, and that changes to the incorrect documents would have to be initiated.
This item will remain unresolved pending review of changes to the Technical Specifications, and to Tabl.e X1.29-1 of the Updated Response to TMI Re-lated Requirements.
(387/81-13-03) 8.
Technical S ecifications Review On June 30, 1981 the resident inspector attended a meeting between members of the licensee staff and NRR to discuss the NRC proof and review copy of the Susquehanna Steam Electric Station Technical Specifications.
Comments from these meetings will be incorporated into a future revision to the Technical Specifications.
9.
0 eratin Staff Trainin On July 8, 1981 the inspector attended a Health Physics Level II training session given by the licensee.
Successful completion of this course is a pre-requisite for unescorted access to controlled areas of the plant after it has been put into operation.
The session covered the following areas: 1.
Radiological llork Permit.
2.
Federal and.Local-Administratiye Exposure Limits,, 3.
(Contaminated Areas,, Radiation Areas, High Radiatien Areas'; 4.
'Use of Self-Reading Dosimeters-and Thermolum'inescent Devices (TLD's).
( 5.
Proper Operation of RADIACS to be Used On Site.
6.
Federal and Local Administrative Recommended Practices Concerning Pregnant Female 'Employees, 7.
Effects of ionizing radiation on personnel, sources of radiation in the plant, and methods to minimize exposure.
Two areas were not covered in the course although these areas were originally listed as course objectives.
These two objectives were donning and removing protective clothing, and entering and exiting contaminated areas properly.
The students attending the course were told they would have to return at a future date to complete these portions of the course.
Two written quizzes were given covering all areas discussed.
Persons receiving a grade below 80Ã on the combined average of the quizzes were required to retake portions of the course.
No unacceptable items were identifie s'h
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Prep erational Test Review a.
Reactor Protection S stem (RPS) Review (1) References: (a) P58. 1 - Revision 1, Reactor Protection Systems (b) FSAR, Section 7.2, Reactor Trip System,(RPS), Instruments and Controls (c) G.E.
RPS Design Specification, 22A3056, Revision
(d) G.E.
RPS Design Specification, Data Sheet, 22A3056AB, Revision (~3 (2) Ins ector Findin s: (a) The inspector reviewed reference)(a).
against references (b),-(c), and (d) to verify that the procedure-addresses-NRC reguirements and licensee commitments re'iating to the RPS.
Specific system per-formance functions reviewed were: Minimum scram reset time; Response time of protection channel; Calibration of components; Verification of above functions; Demonstration of electrical independence, redundancy and safe failure on loss of power; Logic functions; including RPS related Recirculation PuPlp Trip (RPT) logic; Automatic and manual system operations; Instrumentation functions; Mode switch operation; and, Permissive, prohibit and bypass functions
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(b) The inspector noted that covered trip points specified in the acceptance criteria are based upon the Station Technical Specification;<Preliminary Draft - October,91980.
These specifications have not been approved and the setpoints are subject to change.
The inspector further noted that several documents referenced in the test procedure were not the latest revision.
From discussions with the RPS Test Director, the inspector determined that a final review of the procedure would be conducted to verify that the latest reference section drawing and document revisions (including Station Technical Specifications) were incorporated inthe test.
The inspector verified that the Startup Administrative Manual Procedure AD 7.7 - Revision 3, Preoperational/Acceptance Test Implementation approved July 18, 1981 controlled this review.
Based on the above, the inspector had no further questions at this time.
No items of~noncompliance were identified.
(c) Completeness of logic checks was questioned and is unresolved (81-13-04).
ll.
Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are"acceptable items, items of noncompliance, or deviations.
Unresolved items disclosed during the inspection are discussed in Sections 5.a, 5.d, 7.b, and 10.c.
12.
Exit 'Interviews At periodic",intervals during the course of this inspection, meetings were held with facil,ity management to discuss the inspection and findings identifie l>>iiE }}