IR 05000387/1987017
| ML17146B044 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/20/1987 |
| From: | Murphy K, Van Kessel H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17146B043 | List: |
| References | |
| 50-387-87-17, NUDOCS 8711300275 | |
| Download: ML17146B044 (12) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-387/87-17 Docket No.
50-387 License No.: NPF-14 Licensee:
Pennsylvania Power and Li ht Com an 2 North Ninth Street Al 1 entown Penns 1 vania 18101 Facility Name:
Sus uehanna Steam Electric Station Unit No.
Inspection At:
Berwick PA Inspection Conducted:
October 5-9 1987 Inspector:
Henri
.
Van Kesse
,
eact Engineer d te Approved by:
K. G.
Mur y, Acting Chi f Special Test Programs Section, EB, D
S d te Ins ection Summar
Routine Unannounced Ins ection on October 5-9 1987 Ins ection Number 50-387/87-17 Areas Ins ected:
Post Modification Test Program, to be performed during the present refueling outage, including the Post Modification Request (PMR)
packages, post-modification test procedures, and test results for completed post modification tests.
The inspector also reviewed the involvement of gA in the post-modification test program.
Results:,
No violations were identified.
87i L300275 87l f23 PDR
- DOCK 05000387
DETAILS Persons Contacted Pennsl vania Power and Li ht Com an J.
A. Blakeslee, Jr.
R.
G.
Byram, T.
C. Oalpiaz,,
E.
W. Figard, J.
P. Felock, M. M. Golden, G. J. Kuczyaski,.
G.
G. Maerz, D.
F.
McGann, T. Nork, R. J.
Prego, R. 0. Rarig, PE PE Rusanosky, S. 0. Sadvary, 0.
C. Stigora, C.
R. Whirl, Assistant Plant Superintendent Plant Superintendent Technical Supervisor.
I&C/Computer Supervisor Senior Results Engineer Plant Engineer Supervisor IEG Supervisor-Power Production Engineer Compliance Engineer Plant Engineer Supervisor QA Supervisor - Operations Technical Assistant Power Production Engineer Power Production Engineer Power Production Engineer Senior Project Engineer, NQA U. S. Nuclear Re ulator Commission P.
K. Eapen, J. Stair, Section Chief STPS, EB, DRS Resident Inspector Denotes those present in Exit Meeting on October 9, 1987'.
Post Modification Test Procedure Review A number-of design changes and modifications are planned for implementa-tion during the present outage.
The inspector selected 10 major Plant Modification Requests (PMRs)
and 3 minor PMRs.
These PMRs are identified in Attachment A.
In the review of the PMR documentation, the scope of work description and the existence of the safety evaluation were verified to be in accordance with 10 CFR 50.S9(b).
With help of the responsible system engineers the required post modification testing to be done for each selected PMR was established.
These tests may be Categorized as component tests (CTs), Surveillance tests (STs),
or pre-operational tests (PTs).
The type of test and the actual test procedure numbers applicable to the selected PMRs are listed in Attachment All of the PT procedures were reviewed for the following attributes:
d
0 Management review and approval Procedure format Clarity of stated objectives Prerequisites Environmental Conditions Acceptance criteria, and their sources Initial conditions Attainment of test objectives Test: performance documentation and verification Degree of detail for test instructions Restoration of system to normal after testing Qualifications of test personnel Evaluation of test data Independent verification of critical steps or parameter values Quality control and assurance involvement All of the PT procedures reviewed for the above attributes, were found to be adequate except for the QC/QA involvement in the procedures.
None of the PT procedures and the surveillance procedures used in the post modification testing have QA/QC hold points, notification points, or test.
witnessing points for QA's independent verification of the test results.
This observation is discussed in more detail under Section 4 of this report.
. 3.
Post Modification Test Results Review The test results for TP-153-007 (Standby Liquid Control System (SLC)-Controls)
and TP-117-001 (Uninterruptable Power Supply (UPS) to Panel lY128) were reviewed for the following attributes:
Test changes Text. Exceptions Test Deficiencies Acceptance Criteria.
'. Performance Verification Recording of Conduct of test System restoration to normal after the test Independent verification of critical steps or parameters Qualifications of test personnel Verification that the test results have been approved Both tests were completed but the test results were not approved at the time of the inspection.
TP 117-001 (UPS to Panel 1Y128) is not a saf'ety related item.
However, this test was selected, as a system that would eventually assist a safety system.
TP-153-007, is a
PORC approved safety related item.
It was noted in TP-153-007 that.the modified steps in the
procedure section (Section 7) were not dated individually.
The start date and time, however, are shown under steps 6.23 and 6.24.
Another dis-crepancy was the lack of identification of test personnel signing off in the procedure.
Only initials are shown in the sign off spaces and there is no separate full name identification against the initials.
There is, however, a document assignment space on the cover of the procedure which identifies the name of the "user."
The verifiers also are identified by initials only.
The inspector will follow up on these observations in a future inspection; No violations were identified by the inspector.
gAAIL'
f A review was made of the following QA/QC interface items with the plant, modification testing program:
Surveillances performed by QC/QA for the post-modification testing QA/QC requirements for hold points, notification points, and witnessing points for the verification of test preparations and test results.
A number of QA surveillance reports were provided by QA to demonstrate their involvement with modification installation and testing.
These QA surveillance reports are listed in Attachment B.
The available reports and the listing itself indicate adequate involvement in the post-modification test. program in the form of surveillances.
A surveillance check list is used in most cases.
Good findings and observations were made in the completed Quality Assurance Surveillance Reports (QASRs).
With regard to the second attribute above it was determined that the pre-operational test procedures and the surveillance test procedures, used in the post. modification test program, do not-contain hold points, notification points, and witnessing points for the verification of test preparations.
and test results.
This situation is contrary to the commit-ment made in FSAR paragraph 17.2.11 on "test control" which states that these-test procedures
"contain (d) the mandatory inspection hold points for witnessing by PP&L.
Administrative procedure AO-QA-101 reference No. 1, (page 51) says:
"Examples of where Notification Points maybe appropriate include:
"8.3 during post maintenance testing."
Also, examples of where Hold Points may be appropriate include:
"7. 10 Acceptance Criteria verifications
"
The licensee noted that QA audits, performed recently, have made the same observations.
In Reference 3,
recommendation No. 2, it says
"QC has a
mechanism for establishing witness/bold points in General Test (GT) and Work Authorization (WAs).
However, there is no mechanism for establishing witness/hold points in test procedures (TPs) since TPs are typically performed without an implementing WA.
This appears to be a weakness in the post modification testing program and could be construed as a violation of OPS 14 requirements."
OPS 14 states, in part, under "Control of Inspection
and Test," paragraph 5.1.8:
"Inspection requirements for modifications
....shall be equivalent to the inspection requirements of the original design...fPre-operational tests did have gC witness points for acceptance criteria verification steps]."
No action has been taken by the licensee to date on the recommendation 2 of Reference 3.
There is, however, considerable discussion on this observation by the gA Audit team.
This item remains unresolved pending NRC review of licensee actions to address recommendation 2 of Reference 3 below.
(50-387/87-17-01)
References 2.
3.
AD-gA-101, Attachment H, rev.
15, "Guidelines for Establishing Inspection Points."
FSAR 17.2. 11, "Test Control."
"Test Control", dates of Audit:
November 19 to December 5,
1986.
OPS 14, revision 2, "Control of Inspection and Testing."
Inde endent Ins ection Effort A physical inspection was made of the nearly installed components of the Uninterruptible Power Supply (UPS) Unit for panel lY128 (PMR 86-3001AEB).
While. this new equipment is non-safety equipment, it will provide smooth DC power to the instruments and controls of the secondary system (includ-ing Feedwater)
during a. loss of offsite power (LOP) and migimize the dependence on safety related systems by continued operation of secondary systems.
The new UPS equipment has jelly type batteries (Avatron), which are used also in other-industries to back up power supplies to computers during power outages.
These batteries do not develop hydrogen and do not require level checks.
They have a
10 year service life. The installation area has been provided with new HVAC outlets taken 'from the turbine build-ing HVAC.
This HVAC and UPS equipment installation were found to be complete and operating within its normal parameters.
The post modifi-cation testing was completed earlier.
No violations were observed by the inspector.
Plant Tours The inspector made a tour of the plant including the control building, reactor building and turbine building to observe the work in progress, housekeeping, testing activities, and cleanliness.
No unacceptable conditions were noted.
Unresolved Items Unresolved items are matters about which more information is required in order to determine whether they are acceptable, an item of noncompliance, or a deviation.
New unresolved items in this report are identified in Section.
Exit Interview At the conclusion of the site inspection, on October 9, 1987, an exit interview was conducted with the licensee's senior site representatives (denoted in Section 1).
The findings were identified and previous inspection items were discussed.
At no time during this inspection was written material provided to the licensee by the, inspector
.
Based on the NRC Region I review of this report and discussions held with licensee representatives during this inspection, it was determined that this report does not contain information subject to
CFR 2.790 restriction Attachment A
Review of Modification Packa es PMR No.
a~i Tvye Test Proc No.
85-3100B'lternate Rod Insertion Control Panel; ST,PT Changes (ARI)
SI-164-203 TP-100-004 TP-155-011'5-3100C ARI Conduit and Cables ST,PT I
Ditto 85-3097B Stand-by Liquid Control (SLC) Controls ST,PT SO-153-002/3 C
L-153-11/12/13'P-153-003/007 85-3097C SLC PSV Spring Replacement 86-3001A Uninterruptibl e Power Supply (UPS)
to panel 1Y128 (pre-outage)
86-3001C UPS to panel 1Y218 (pre-outage)
TP TP Cancelled TP-117-001 TP-117-002 86-3001B 86-3001D 86"3001E 85"3142 83-0523 UPS to panel 1Y128 (outage)
,LOOP UPS to panel 1Y218 (outage)
, LOOP Cable and Raceways, LOOP, HVAC'work FM-LLRT, valves, vents, and drains.
Replace 200 VDC input breaker TP TP TP ST
. CT,ST TP"117"001 TP-117-002 Completed S0-161"001 SO"161"015 SM-188-103'0 IV.1)
SM-188-203 (DIV.2)
MT-GE-008/9 86-7016 250 VDC Battery Modificati ons 87-9089 HPCI Booster Pump Impeller.
~
Le end CT-Component Test.
I ST-Surveillance Test.
PT-Pre-operational Test.
CT,PT ST,PT Ditto SO"152-005/002 TP"152-009
Attachment B
QA Survey Re ort No.87-198 87-xxx 87-200 87-201 87-215 87-216 87-218 87"225..87-224 87-222 87-221 87"174 87-202 A Surveillances For Modifications Descri tion Implementation of PMR 86-3001A, B
,TP-117'-01 UPS for 1Y128 panel
.
Standby Liquid Control, Surv. Proc.
SC-153-101 Replacement RC Snubber Network on ID663-250 Volt battery charger,
,PMR 86"7016 Replacement of input breaker on 250 V battery charger RPS fuse/f use cl i p chang eout, PMR 86"8015 Post Div II 250 V Battery Changeout
,TP-188-005, Div II battery 1D660 enhanced performance test Installation of redundant breakers for hydrogen recombiners ATWS-ARI, PMR 85-3100B Instal 1 ation conduit/cable and installation RWCU FW Return line conU i sol. val ve Witnessing surveillance test SE-151'-002,
"18 mos Core Spray System'nd logic funct. check loop B
Witnessing surv. test SM-104-002,
"18 Months Calibr.
4kV Bus lA202 relays Witnessing TP-211-004, Service Water for Unit 1 from Unit 2, during refuel ing I&C/PMR 86-3008F,
"Calibration of TSHL 18201B."
Status of SAR Draft Report Planned Planned test coverage; work covered.
Ditto Work covered, draft report Test covered Work in progress Planned Work in progress Report. being Written Ditto Report complete Report complete
QA Surv.
Re ort No.87-141 87-xxx 87-085 87-066 Attachment B
A Surveillance For Modifications Descri tion complementation of PMR 86-7016 Post Maintenance Testing Post Maintenance Testing TP-024-065, Emerg.
Diesel generator
"E", startup test.
Status of SAR Report Complete Work in progress Report Complete Report Complete