IR 05000410/1986038

Insp Rept 50-410/86-38 on 860714-24.No Violation Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings, Preoperational Test Results Evaluation Review & Power Ascension Test Program

ML20205G818
Person / Time
Site:	Nine Mile Point
Issue date:	08/07/1986
From:	Eselgroth P, Marilyn Evans, Florek D, Vanterpool E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17055C207	List: IR 05000410/1986038
References
TASK-2.K.3.21, TASK-TM 50-410-86-38, NUDOCS 8608190630
Download: ML20205G818 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-38 Docket N License N CPPR-112 Category B Licensee: Niagara Mohawk Power Corporation 100 Erie Boulevard West Syrtcuse, New York 13202 Facility Name: Nine Mile Point Nuclear Station, Unit 2 Inspection At: Scriba, New York Inspection Conducted: July 14-24, 1986 Inspectors: ./ JN

D. Florek, Lead Reactor Engineer I c) ate N, k lo M. Evans, Reactor Engineer ' date M Ib E. Vanterpool, Summer Intern "

'date Approved by: T 5 P. EseM r Chief, Test Programs ' dite Sectio perations Branch, DRS Inspection Summary: Inspection on July 14-24, 1986 (Inspection Report No. 50-410/86-38)

Areas Inspected: Routine unannounced inspection by two region based inspectors and a summer intern of licensee action on previous inspection findings, preoper-ational test results evaluation review, the power ascension test program includ-ing the overall program and test procedure review; QA/QC interfaces; independent measurements and verification, and facility +ours and n'9eting Results: No violations were identifie NOTE: For acronyms not defined refer to NUREG-0544, " Handbook of Acronyms and Initialism".

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8609190630 860811 PDR O ADOCK 05000410 PDR l

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i DETAILS 1.0 Persons Contacted l Niagara Mohawk Power Corporation R. Abbott, Station Superintendent, NMPC S. Agarival, Senior Licensing Engineer G. Carlisle, Lead STO and A Engineer, GE

• J. Conway, Power Ascension Manager, NMPC

1. J. Drake, Startup Special Projects Supervisor (SWEC)

l # W. Hansen, Manager, Nuclear Quality Assurance (QA) Operations l J. Halusic, System Test Engineer l # T. Lee, Special Projects

J. McKenzie, Quality Surveillance Supervisor L. Ringlespaugh, Test Coordinator J. Robles, GE Site Operations Manager, GE

• I. Weakley, Special Projects, NMPC

• P. Wielde, Supervisor, Surveillance QA U.S. Nuclear Regulatory Commission

1. • W. Cook, Senior Resident Inspector

• Denotes those present at interim exit held on July 18, 198 # Denotes those present at the final exit on July 24, 1986.

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2.0 Licensee Actions on Previous Inspection Findings l (Closed) Construction Deficiency Report (410/86-00-03) Failure of RPS trip l

I on high thermal power. Based on review of Engineering and Design Coordin ator Report (E&DCR) No. C46438, Field Deviation Disposition Request (FDDRJ

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No. K61-4895, and letter GE to Stone and Webster dated April 24, 1986, the inspector concurred with the licensee that the item was not reportable under 10 CFR 50.55(e). This item is close (Closed) Unresolved Item (410/86-20-01) Licensee to resolve three open test deficiencies concerning precperational test procedure N2-P0T-32, Low l

f Pressure Core Spray. The inspector reviewed deficiency reports (DR's)

13885, 13615 and 11203 and noted that appropriate corrective actions, retests l and Quality Control Inspections had been accomplished. Also the i inspector verified that DR 13885 received Joint Test Group (JTG) approval as required. This item is close l l

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(Closed) Unresolved Item (410/86-29-04) Three Mile Island (TMI) Action Plan Task No. II.K.3.21, Restart of Core Spray and Low Pressure Coolant Injection System. The licensee committed to modify the High Pressure Core Spray (HPCS) actuation logic to include an automatic restart capabilit The HPCS pump will auto-restart on low reactor vessel water level if the pump has been stopped manually. The inspector discussed the HPCS auto-restart actuation logic with a licensee representative and reviewed appro-priate General Electric (GE) Elementary Drawings. The inspector reviewed the results of preliminary test procedure EE. GENE.006, Control Circuit Verification, Revision 5, to verify proper testing of the HPCS relay logi The inspector also reviewed the results of Sections 4.12 and 4.13 of pre-operational test procedure N2-POT-33, High Pressure Core Spray, Revision 1 and verified that proper system operation had been demonstrated. This item is close (Closed) Unresolved Item (410/85-25-03) Licensee to identify the preopera-tional test procedures (POT) in which compliance to three diesel generator preoperational test requirements is demonstrated. The inspector reviewed test procedure N2-POT-300, Loss of Offsite Power /2CCS, Revision 1 and veri-fied that the redundant diesel generators are started simultaneously during the reliability demonstration to identify potential common mode failure The inspector reviewed field revision form (FRF) #1 to preliminary test procedure MD.0100.A04, Standby Diesel Generator Air Start Capacity Test, Revision 0, and verified that the preliminary procedure had been revised to demonstrate the diesel air start system capacity for five consecutive starts (instead of two) to rated speed and voltage within ten second Also, the inspector reviewed a log, compiled by the licensee, of diesel generator starts subsequent to completion of the diesel generator reliabi-lity demonstration. The inspector noted that periodic diesel generator testing was being accomplished as required. This item is close (0 pen) Unresolved Item (50-410/86-27-01) Licensee to include a list of deficiencies, the status of the deficiencies, and the supporting closure documentation in all preoperational test packages. During Inspection 50-410/86-33, the inspector noted several deficiency reports (DRs) and problem reports (prs) which were not properly annotated as Joint Test Group (JTG) open action items on the licensee's Master Tracking System (MTS). Subsequent to that inspection, the licensee audited its tracking system, and identified several more discrepancies. The inspector discuss-ed this with a licensee representative wno stated that the tracking system will be audited weekly in order to assura that JTG open action items are properly tracke In addition, the inspector reviewed the preoperational test package for POT-100-Al (previously reviewed in Inspection 50-410/86-33) and noted that supporting closure documentation fer three recently closed DRs and one PR was included in the test package. This item will remain open pending ad-ditional review of approved preoperational test result package ._

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3.0 Preoperational Test Results Evaluation Review 3.1 Scope

The completed test procedures listed below were reviewed during this l inspection to verify that adequate testing had been conducted to sa-tisfy regulatory guidance, licensee commitments and FSAR requirements .

and to verify that uniform criteria were being applied for evaluation I of completed test results in order to assure technical and administra-tive adequac .2 Discussion The inspector reviewed the test results and verified the licensee's evaluation of test results by review of test changes, test exceptions, test deficiencies, "As-Run" copy of the test procedure, acceptance criteria, performance verification, recording conduct of test, QC inspection records, restoration of system to normal after test, inde-pendent verification of critical steps or parameters, identification of personnel conducting and evaluating test data, and verification that the test results have been approve N2-P0T-97, Reactor Protection System (RPS), Revisien 1, Station Operations Review Committee (SORC) approved on June 26, 198 N2-P0T-92.3, Power Range Monitoring System, Revision 1, SORC approved on May 23, 1986. (Inspector only reviewed sections relating to RPS.)

3.3 Findings No violations were observed. One open test deficiency, DR #19649, con- 1 cerning N2-POT-97 will be carried as an unresolved item (410/86-38-01) i pending licensee resolution and subsequent NRC revie .0 Power Ascension Test Program 4.1 References -

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Regulatory Guide 1.68, Revision 2, August 1978 " Initial Test I Programs for Water-Cooled Nuclear Power Plants"

ANSI N18.7-1976 " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants"

Nine Mile Point Unit 2 (NMP-2) Technical Specifications Final Draft June 25, 1986

NMP-2 Final Safety Analysis Report (FSAR), Chapter 14 " Initial Test Program" l

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I NMP-2 Safety Evaluation Report l

4.2 Overall Power Ascension Test Program Administration  ;

4. Scope 1 The inspector reviewed the following procedures:

AP-1.4, "Startup Test Phase", Revision 1 draft, dated May 1986 AP-8.7, " Power Ascension Test Procedures", Draft copy dated l April 1986 '

AP-2, " Production and Control of Procedures", Revision 5, dated June 198 The inspector discussed with the Power Ascension Manager (PAM) the ap-proaches taken to assure adequate implementation of the power ascen-sion program. Training and staffing were also discussed. The inspec- l tor reviewed the administrative procedures to determine whether ade- '

quate controls exist to assure that test procedures are current prior to use, test personnel are knowledgeable, controls exist for test procedure changes, interruptions in test are controlled, proper test coordination, documentation of unusual events and test deficiencies, test results are reviewed, test acceptance criteria are defined, re-test after test deficiencies and appropriate revie The inspector also held discussions with the Supervisor QA Surveil-lance to determine their plans for the power ascension test progra . Discussion Inspector review of the procedures identified the following items which the licensee representative agreed to include in the administra-tive procedure *

Clarifying test exception tracking and control for those test exceptions which may carry over into a subsequent test platea *

NRC approvals for changes to the Power Ascension program need not be more restrictive than required by the operating licens *

Methodology to assure that test procedure changes are approved prior to or concurrent with approval of test results.

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Station Operations Review Committee (SORC) review of resolution to exceptions to Level 1 acceptance criteria prior to release of the plant test HOLD conditio With the addition of the above items, the inspector had no further questions regarding the administrative controls. These will also be reviewed in a subsequent inspection when the procedures are finalize The Power Ascension Manager (PAM) described the organization to imple-ment the power ascension test program (PATP). The licensee will uti-lize 5 shifts during the program with a mixture of GE, S&W and NMPC personnel as test engineers. Staffing levels are established. Four key shift test supervisors are on site with one to arrive within a few week Training for station personnel is in progress. Three levels of train-ing are planned. Administrative Procedure Training for Normal Station personnel will soon commence. Overall PATP training for operators, reactor analysts, QA personnel and test engineers has started and will continue. Detailed Test Engineer Training is also being develop-ed and will be provided prior to beginning a test condition throughout the program. Whereas the detailed training material was not reviewed by the inspector, the overall approach was considered acceptabl Discussions with the Supervisor Surveillance QA indicated that QA will review all test procedures, perform surveillance activities 'of selected tests and review all completed test results. Checklists are being develope . Findings No violations were identifie .3 Power Ascension Test Program Procedure Review 4. Scope The procedures of Appendix A were reviewed to determine the degree of compliance with the following attributes:

Appropriate management review and approval has been accomplishe *

Appropriate committee review has been accomplishe *

Procedure is in the proper forma *

Test objectives are clearly stated and consistent with the FSAR.

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Appropriate references are liste *

Appropriate prerequisites and precautions have been include *

Initial test conditions are specifie *

Acceptance criteria are clearly state *

Provisions have been made to identify test equipment utilize Provisions have been made to identify personnel performing the tes * {

The procedure is technically adequate and workabl '

A Provisions have been made for recording, evaluating and approving test dat *

Provisions have been made to identify test deficiencies and exceptions and to document their resolution ;

4. Discussion Based on questions from the inspector, the licensee representative agreed to include the following in the appropriate procedures:

N2-SVT-1-0V Limits for conductivity and chlorides should be consistent throughout the procedur *

N2-SUT-3-0V Inspector reviewed the draft copy plus comments identified by the licensee reviewers. Licensee comments will resolve inspector question *

N2-SUT-5-0V Test criteria for friction settling limits was not consistent in procedures N2-SUT-5-0V and reference procedure N2-IMP-CRD- *

N2-SUT-6-HU Source range monitor (SRM) trip setpoint should be lowered until completion of ncn-saturation tes Specify Operability of all SRM's for initial criticalit Define "on scale" for SRM/IRM overlap. Use irdividual SRM normalizations versus average SRM normalization for SRM/IRM overlap. . Clarify that satisfactory completion of shutdown margin test in addition to the SRM/IRM overlap and SRM nonsaturation testing is required prior to installation of the shorting link *

N2-SUT-12-HU The range of plant conditions that the methodology used to perform the calibration is applicable should be specifie Clarify that actual APRM gain adjustments should occur at a constant power level, u_

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N2-SUT-16-HU Clarify where the shutdown level range check is performe Licensee will provide the analysis regarding level variation as a function of reactor building temperature variatio *

N2-SUT-17-HU Clarify when the analysis steps are performed, at the intermediate temperatures or at rated temperature. Resolve potential inconsistency with the Section 8.0 Note and the' analysis step for Level 1 Acceptance criteria on interpretation of tests dat *

N2-SUT-75-HU Specify applicable temperature limits for the undervessel are Not all procedures of Attachment A were issued nowever, the review process was essentially completed for all. Based on the items generated by the inspector review, the inspector was concerned on the adequacy of the li-censee review proces The licensee recognized that they had inconsistencies with startup test procedures and had established a followup review of all revision 0 issued procedures to verify that the procedures were compatible with plant proce-dures, correct and workable. In addition, the licensee had planned to utilize the procedures on the plant simulator as part of the training pro-gra Based on the licensee pre established plans to conduct a followup review of the startup procedures and use of the simulator the inspector will consider the adequacy of the licensee startup procedure review pro-cess unresolved pending implementation and effectiveness of the foliowup review (50-410/86-38-02).

4. Findings No violations were identif(e .0 QA/QC Interfaces 5.1 Power Asce'nsion Test Program The QA plans for the power ascension test program are discussed in Section 4.1. QA signatures were noted in the issued power ascension test procedure .2 Preoperational Test Program

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The inspector reviewed several recent Nuclear Quality Assurance Surveillance Reports (QASR) regarding different activities of the licensee's startup department. The following QASR's were reviewed:

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QASR 86-1G569, surveillance of troubleshooting of Main Steam Isolation Valve (MSIV) #7A, completed on July 16, 1986. During performance of preoperational test N2-POT-1, Main and Auxiliary Steam Systec Revision 1, the eight MSIV's were tested for fast closure (3 to 5 sa onds) on an emergency trip. Seven of the MSIV's performed satisfactorily. However, the closing time for MSIV #7A was greater than ten seconds. The QA inspector witness-ed the troubleshooting of the MSIV performed by the Startup and Test (SU&T) departments. SU&T concluded that excess fluid in the MSIV's hydraulic system was causing the greater than accept-able valve closure times. SU&T removed the excess fluid and retested the MSIV. The valve closed within the specified time on each of three retests. The QA inspector noted that the sys-tem test engineer appropriately documented the MSIV troubleshoot-ing and retesting in the test summary of the procedur QASR 86-10574, surveillance of retesting of portions of preopwa-tional test N2-POT-1.' Service Water System, performed on July 9, 1986. Retesting of 5sveral annur:.tators was conducted under deficiency report (I R) 17024. ihe QA inspector noted that all retesting was perfo med satic.factoril In addition to the above, the inspector reviewed the resolution of QASR 86-10519, which was initially reviewed during Inspection 50-410/86-31, and discussed the resolution with a licensee QA representative. The QASR identified changes made to preopera-tional test (POT) packages after Joint Test Group (JTG) approval of the completed procedure. The corrective action implemented was the transmittal to QA, for review and comment, copies of all documents to be added to POT packages and the JTG review of all documents added to POT package .3 Findings No violations were identified within the scope of the above revie .0 Independent Measurements and Verifications I i

During the power ascension test procedure review, the inspector verified adequacy and consistency among procedures. The results of the review are discussed in Section l L

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1 7.0 Facility Tours and Meetings 7.1 Tours The inspector made several tours of various areas of the facility in-cluding the drywell, reactor building, control structure and turbine building to observe work in progress, housekeeping, cleanliness and status of coi.struction. The inspector observed a much improved over-all plant appearance; more typical of a plant approaching initial fuel loa .2 Meetings The inspector randomly attended the licensee's morning Startup Plan of the Day meeting during which the current status of preoperational testing activities and any holds or delays are discussed. Other items such as surveillance and outage activities are also discusse .3 Findings No anacceptable conditions were observe .0 Unrest,1ved Items Unresolvad items are matters about which more information is required in order to ascertain whether they are acceptable, an item of noncompliance ,

or a deviation. The unresolved items identified during this inspection '

are discussed in Paragraphs 3.2 and 4.3 of this repor l 9.0 Exit Interview A management meeting was held at the conclusion of the inspection on July 24, 1986 to discuss the inspection scope, findings and observations as detailed in this report. An interim exit meeting was also held on July 18, 1986 to discuss preliminary inspection findings (see Paragraph 1 for attendees at both meetings). No written information was provided to the licensee at any time during this inspection. The licensee did not indicate that any proprietary information was contained within the scope of this inspectio l C__--_________________-.____

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APPENDIX A Power Ascension Test Program Procedure Review N2-SVT-1-0V, Chemical and Radiochemical, Revision 0 Issued June 11, 1986 N2-SUT-2-0V, Radiation Measurements, Revision 0 Issued May 2, 1986 N2-SUT-3-0V, Fuel Movements, Revision 0 N2-SUT-5-0V, Control Rod Drive System, Revision 0 N2-SUT-6-HU, SRM Performance, Revision 0 N2-SUT-10-HU, IRM Performance, Revision 0 N2-SUT-12-HU, APRM Calibration, Revision 0 N2-SUT-16-hU, Selected Process Temperature and Water Level Measurements, Revision 0 Issued June 16, 1986 N2-SUT-17-HU, System Expansion, Revision 0, Issued June 3, 1986 N2-SUT-70-HU, Reactor Water Cleanup System, Revision 0 Issued June 3, 1986 N2-SUT-75-HU, Drywell Cooling System, Revision 0 Issued June 12, 1986 N2-SUT-78-HU, BOP System Expansion, Revision 0 NOTE:

Those procedures not indicated as " issued" are copies in the review cycl !

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