IR 05000400/1985047

Insp Rept 50-400/85-47 on 851202-06 & 16-20.Violation Noted: Failure to Provide Appropriate Acceptance Criteria & Identify Data Recorder for Certain Sets of Data in Test Procedure 1-2005-P-01 Re Hot Functional Test

ML18019A565
Person / Time
Site:	Harris
Issue date:	01/17/1986
From:	Jape F, Taylor P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18019A563	List: IR 05000400/1985047 ML18019A562 ML18019A564
References
50-400-85-47, NUDOCS 8602040235
Download: ML18019A565 (14)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323 Report No.:

50-400/85-47 Licensee:

Carolina Power and Light Company P. 0.

Box 1551 Raleigh, NC 27602

.Docket No.:

50-400 License No.:

CPPR-158 Facility Name:

Harris Unit

Inspection Conducted:

December 2-6 and 16-20, 1985

,

Inspector:

P. A. Tay or Approved by:

F. Jape, Section C ief Engineering Branch Division of Reactor Safety i rP P4 Date Signed

/ I> S'4 ate Soigne SUMMARY Scope:

This routine, unannounced inspection involved 70 inspector-hours on site in the areas of hot functional controlling procedure review, preoperational test procedure review, preoperational test witnessing, and plant tour.

Results:

One violation was identified - Failure to provide appropriate acceptance criteria and identify the data recorder for certain sets of data in test procedure 1-2005-P-01, Hot Functional Test Procedure.

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REPORT DETAILS 1.

Persons Contacted Licensee Employees 0'J.

L. Harness, Assistant Plant General Manager

• PC. S. Hinnant, Manager, Startup PE. J. Wagner, Manager, Engineering

• IN. J. Chiangi, Manager, Quality Assurance/Quality Control (QA/QC)

• 8G. L. Forehand, Director, QA/QC PG.

W. Traylor, Startup Supervisor - Nuclear Steam Supply Systems (NSSS)

8C.

E. Rose, Jr.,

QA Supervisor PR. J.

Duncan, Startup Engineer 8B.

H. Clark, Startup Engineer

• 8M. G. Wallace, Specialist, Regulatory Compliance O'. T. Biggerstaff, Principle Engineer

• P.

W. Howard, Specialist, Regulatory Compliance J. Dority, Startup Supervisor, Electrical Other licensee employees contacted included engineers, operators, and office personnel.

NRC Resident Inspectors

• G. F. Maxwell 8S.

P. Burris

• Attended exit interview of December 6,

1985 8Attended exit interview of December 20, 1985 2.

Exit Interview The inspection scope and findings were summarized on December 6 and 20, 1985, with those persons indicated in paragraph 1 above.

The inspector described the areas inspected and discussed in detail the inspection findings.

No dissenting comments were received fromthe licensee.

a.

Inspector Followup Item 400/85-47-01, Clarify Method to Ensure Initial Condition 2.9 of Test Procedure 1-1100-P-01 Will Be Met for All Systems and Yalves, paragraph 6.

b.

Unresolved Item 400/85-47-02, Correct Discrepancies in Test Procedure 1-1100-P-02, Containment Isolation Test, paragraph 6.

c.

Unresolved Item 400/85-47-03, Clarify Acceptance Criteria, Evaluate, and Correct Discrepancies in Test Procedure 1-2005-P-01 -

Hot Functional Test, paragraph 'E<<<<<<f I tl Mtt 4th 'r

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Violation 400/85-47-04, Failure to Provide Appropriate Acceptance Criteria and Identify the Data Recorder For Certain Sets of Data In Test Procedure 1-2005-P-01, Hot Functional Test Procedure, paragraph 5.

The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.

3.

Licensee Action on Previous Enforcement Hatters This subject was not addressed during the inspection.

4.

Unresolved Items Unresolved Items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations.

New unresolved items identified during this inspection are discussed in paragraphs 5 and 6.

5.

Review of Hot Functional Sequencing Procedure (70308)

a ~

The licensee approved on 12/11/85, Hot Functional Test Procedure 1-2005-P-Ol, Revision 0.

This procedure is used to control and sequence hot functional testing during the heatup of the reactor coolant system (RCS) to normal operating conditions and the subsequent cooldown demonstration of the RCS.

This test procedure was reviewed to confirm that:

The test procedure is consistent with FSAR Chapter

and Regulatory Guide 1.68 commitments regarding demonstration of component and system operability in all modes and throughout full design operating range.

Thermal expansion, vibration (piping and reactor vessel internals)

and restraint tests are scheduled during hot functionals.

Water chemistry controls are established.

Preconditioning criteria for RCS internals are established.

Overall plant testing has been identified and scheduled to be performed.

Plant procedures are checked to determine their adequacy.

The test procedure contained the required reviews, management approvals, precautions and acceptance criteria.

The review of the controlling procedure for hot functional testing resulted in an unresolved item and a violatio >>4 Uh.,"U I

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b.

Unresolved Item (400/85-47-03)

(1)

Provide acceptance criteria in section 7.5; for the temperature requirements when operating RCS at full flow conditions for a

minimum of 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br />.

(2)

Provide acceptance criteria regarding the operating time and chemistry criteria necessary to establish the passivating film in the RCS.

C.

The licensee indicated that the time period required for RCS passivation wi 11 be determine prior to completing hot functional testing.

A management decision on whether to follow Westinghouse recommended passivation time period is also under review.

(3)

Preoperational test 1-1100-P-01, Containment Isolation Response Time requires testing isolation valves at normal operating temperature and pressure.

This procedure is not scheduled to be accomplished during hot functionals yet certain isolation valves require the RCS to be at normal operating conditions for the test.

(4)

Section 6.2.11.8 provides the necessary steps for performing the operational test of Safety Injection System Check Yalves.

The primary means for determining check valve operability is by acoustical noise when water flows through the check valve(s).

Presently, no sound listening device (e.g.,

sounding rod on stetho-scope)

is being considered to detect the acoustical noise.

The licensee indicated that the above concerns would be reviewed and appropriate changes made to test procedure 1-2005-P-01.

Violation (400/85-47-04)

The inspector reviewed test procedure 1-2005-P-01 Purpose/Objective Section 1.0; Detail Procedure Steps Section 6.0; and Acceptance Criteria, Section 7.0, to verify that by performing the detailed procedure steps and collecting the data required to be recorded in Section 10 the test objectives and the acceptance criteria will be met.

The licensee provided acceptance criteria 7. 1 and 7.2 which reads as follows:

7.1 Reactor Coolant System heatup has been satisfactorily demonstrated within the limitations listed or referenced in the steps of this procedure (Section 6.1).

7.2 Supporting systems and components have demonstrated satis-factory operation as described in the steps of this procedur hi<

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When examining the detailed procedure steps and the data collected in Section 10, it appears that no appropriate acceptance criteria, acceptable operating ranges, nor limitations are provided in order to evaluate the data recorded to ensure expected results have occurred.

The data collected appears to be general in nature (e.g.,

baseline data, operational data, and precautionary data so as not to exceed limits) and affect the following sets of data:

10.2 Reactor Coolant Pump Data 10.4 Incore Cooling (ICC) Monitor 10.5 81 Seal Data w/RCPs Secured 10.8 81 Seal Data w/RCPs Energized 10.9 Containment Ventilation Data 10. 18 CRDM Cooling Fan Temperature In addition to the above concern, the inspector found that several sets of data did not contain a verification signature or date.

The observer and data recorder who participated in the test are not identified.

The following sets of data do not identify the observer or data recorder:

10.2, 10.4, 10.9, 10.10, 10.11, 10.12, 10.13, 10.14, 10.16, 10.18, 10.19, 10.20, 10.21, 10.22, and 10.23.

The inspector informed the licensee that the above findings appear to violate

CFR 50, Appendix B, Criterion V and the accepted gA program (FSAR Chapter 17.2)

which requires that instructions, procedures, or drawings include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satis-factorily accomplished.

CFR 50, Appendix B, Criterion XVII and the accepted gA program (FSAR Chapter 17.2)

which requires that test records shall, as a minimum, identify the inspector or data recorder, the type of observation, the results, the acceptability and the action taken in connection with any deficiencies noted.

The licensee indicated that the above concerns would be reviewed and appropriate changes made to test procedure 1-2005-P-01.

The item is identified as violation 400/85-47-04, Failure to Provide Appropriate Acceptance Criteria and Identify the Data Recorder for Certain Sets of Data in Test Procedure 1-2005-P-01, Hot Functional Test Procedure.

6.

Preoperational Test Procedure Review (70300B, 70344)

The inspector reviewed several licensee prepared and approved preoperational test procedures to verify that the technical content in the procedures is consistent with FSAR Chapter 14.2 test program and RG 1.68, Revision

requirement and commitments.

The test procedures were also reviewed to verify that the requirements of Harris Plant Startup Manual Volume I have been incorporated into the test procedures regarding preparation, reviews, management approval, procedure format, and the required prerequisites, precautions, and acceptance criteri H 4<<e

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The review of test procedures resulted in the following comment on two test procedures:

a.

1-1100-P-01, Containment Isolation Response Time Test, Revision

(1)

Prerequisites and Initial Conditions 2.9 requires that each containment isolation valve be tested at normal system operating temperature and pressure.

The inspector pointed out that the procedure doesn't presently provide sufficient documentation and sign-off so that initial condition can be verified prior to beginning the test.

Since more than 100 valves are to be tested and involve several systems (e.g., ventilation, air, water),

one sign-off in the procedure appears inadequate as an appropriate method for varifying conditions for each system.

This item is identified as Inspector Followup Item 400/85-47-01, Clarify Methods To Ensure Initial Condition 2.9 of 1-1100-P-01 i<ill Be Met for All Systems and Valves.

b.

1-1100-P-02, Containment Isolation Test (1)

Containment isolation valves, per FSAR Table 6.2.4-1, SP-408 and SP-409, are missing from data sheet of Sections

and 12.

These valves should be added.

(2)

Section 10 data sheets need to include a verification check that the include a verification check that the containment isolation valves reach their isolation or closed position.

The data sheets as written are lacking this verification.

These discrepancies are identified as Unresolved Item 400/85-47-02, Correct Discrepancies in Test Procedure 1-1100-P-02, Containment Isolation Test.

7.

Preoperational Test Witnessing (70312, 70438, 70433, 70441)

The inspector observed portions of the following tests:

a.

1-3065-P-01, Revision 1, Auxiliary Feedwater System Controls and Logic Test The inspector observed portions of Section 6. 1 and 6.2, the checkout of auxiliary feedwater pump lA and 1B breaker controls, interlocks and alarms.

The detailed steps of the procedure simulated signals to initiate the aforemention conditions.

The inspector witnessed the establishing of prerequisites and initial conditions for the tests and observed the test engineer's conduct regarding test coordination, recording of data, and the evaluation of the test results against the acceptance criteria.

Problems were not identified with the equipment being tested during the performance of these step P

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1-2060-P-04, Revision 0, CVCS RCP Seal Injection Test The inspector observed portions of Sections 6. 1 and 6.2 which is the verification of RCP-A and B seal injection flows and alarm setpoints.

The inspector witnessed the establishing of prerequisites, initial conditions for the tests.

Also, observed was the test engineer's conduct regarding test coordination, recording of data, and the evaluation of test results against the acceptance criteria.

Problems were not identified with the equipment being tested during the performance of these steps.

Within the areas inspected, no violations or deviations were identified.

8.

Plant Tour The inspector toured the control room, reactor auxiliary building, contain-ment, containment annulus, and outside plant areas to observe work activities in progress, housekeeping, and tag controls on equipment.

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