IR 05000412/1987031

Insp Rept 50-412/87-31 on 870406-17.No Violations Noted. Major Areas Inspected:Startup Program & Test Procedures Review

ML20213G793
Person / Time
Site:	Beaver Valley
Issue date:	05/11/1987
From:	Eselgroth P, Florek D, Wen P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20213G711	List: IR 05000412/1987031 ML20213G709
References
50-412-87-31, NUDOCS 8705180449
Download: ML20213G793 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-31 Docket N License No. CPPR-105

' Licensee: Duquesne Light Company P. O. Box 4 Shippingport, Pennsylvania 15077 Facility Name: Beaver Valley Unit No. 2 Inspection At: Shippingport, Pennsylvania Inspection Conducted: April 6-17, 1987 Inspectors: , C. h\ Pw s 6 87 D. Florek, Lead Reactor Engineer date 3Nv C. M P. Wen, Reactor Engineer s/ s lt ~1 i date A/ -

Approved by: 3 /!87

'P. W. Esel / date

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, Chief Operation ranch, DRS Inspection Summary: Inspection on April 6-17, 1987 (Inspection Report N /87-31)

Areas Inspected: Startup program and startup test procedures revie Results: No violations were identifie NOTE: For acronyms not defined refer to NUREG 0544, " Handbook of Acronyms and Initialisms".

8705180449 870511 7

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gDR ADOCK 05000412 PDR

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r DETAILS 1.0 Persons Contacted Duquesne Light Company A. Brunner, Refueling Supervisor

+*D. Claridge, Compliance Engineer

• N. Daugherty, Director Systems Testings J. Dusenberry, QA Surveillance

+*J. Godleski, Senior Test Engineer

• D. Hunkele, Director QA Operations

+*J. Johns, Supervisor QA Surveillance C. Kirschner, Supervisor QA Audits

• R. Martin, Manager Regulatory Affairs

+ T. McGourty, Senior Test Coordinator

+*T. Noonan, Assistant Plant Manager

+*L. Rabenau, Lead Compliance Engineer

• J. Spiegel, Senior Test Engineer

• G. Wargo, Assistant Director QC D. Williams, Chairman Joint Test Group

+*T. Zyra, Director Site Test and Plant Performance Stone and Webster Engineering Corporation

+ G. Byrnes, Assistant Project Manager

+ R. Wittscnen Licensing Engineer U. S. Nuclear Regulatory' Commission

• J. Beall, Senior Resident Inspector

+*L. Prividy, Resident Inspector The inspector also contacted other administrative and technical licensee personnel during the course of the' inspectio * Denotes those present at interim exit meeting held on April 10, 198 + Denotes those present at final exit meeting held on April 17, 198 .0 Startup Test Program 2.1 References

Regulatory Guide 1.68, Revision 2, August 1978, " Initial Test Programs for Water Cooled Nuclear Power Plants" ANSI N18.7-1976 Administrative Control and Quality Assurance for the Operational Phase at Nuclear Power Plants

Beaver Valley Final Safety Analysis Report, Chapter 14 Initial Test Program

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2.2 Test' Program Review The inspectors reviewed the licensee's administrative procedures as listed in Attachment These procedures were reviewed to: Verify that the licensee has prepared a description of the startup test progra . Verify that a formal program for evaluation of test results have been establishe ' Verify that formal measures have been established which control Test Procedure processes for review, approval, revision and issuanc . Verify that the operating organization has been assigned overall control of all startup test activitie . Verify that the interface between test engineers and the operating organization are specified in writin . Verify that organizational responsibilities are clearly established in writin . Verify that formal administrative measures have been established governing the conduct of testing including:

methods for verifying a test procedure is current prior to its use, methods to assure personnel involved in the conduct of a test are knowledgeable of the test procedures, methods to change (both major and minor) a test procedure during the conduct of testing, criteria for interruption of a test and continuation of an interrupted test, methods to coordinate the conduct of testing, methods to document significant events, unusual conditions, or interruptions to testing, and methods for identifying deficiencies, documenting their resolutions, and documenting retestin In addition to review of the procedures, the inspector held discussions with the Director of Testing and Plant Performance and the Chairman of t ie Joint Test Group.

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The licensee's apptnach to conducting the startup test program is to build on the experit,ce gained during the preoperational test

, program and modify th7 controls to be consistent with the FSAR commitments, technical specifications and the facility license when issue . . . _ _ _ _ _ . _ -_ ._- . . _ - _ . - _ _ _ . - _ - _ . , - . - _ _ _ _ _

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While the controls in place during the preoperational test program are sufficient for that phase, by necessity, once the operating license is issued and nuclear fuel is affected, the controls are even more restrictive. The licensee's procedures and program, were found to be lacking the following:

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The program lacks a site level integrated document for the administrative requirements of startup testing. The organization, duties and responsibilities of review groups (Joint Test Group, On-Site Review Committee) and line functions (test engineers, test supervisors, Director of Testing & Plant Performance, Operations Director, Nuclear Station Supervisor and Plant Operators) are not clearly specified and define The Joint Test Group had not prepared a procedure for their review function during the startup phas In addition, the inspector noted that some of the controls referenced in the administrative procedures are not applicable following the issuance of the operating license, such as the Procedure Review Committee and construction deficiencie These subjects were discussed with the plant management. At the end of this inspection period, the inspector noted that the site testing organization is being reorganized to reflect the current status of the startup test progra The sequence of testing is described in startup test procedure, IST-2.01A.10, "Startup Testing Program" Revision 0. This test procedure outlined the steps in the testing sequence, specified guidelines at appropriate points, and reference detailed test procedures and data collections. The inspector noted that four tests: IST-2.01A.04 (RCCA Bank and Boron Worth Measurement), IST-2.01A.05 (RCCA Pseudo Ejection at Zero Power), IST-2.01A.06 (RCCA Drop Test at 50 Percent Power, and IST-2.01A.09 (RCCA Pseudo Ejection at Power) have been deleted from the startup test progra Through telephone discussion with the NRR Licensing Projget Manager and FSAR Technical Reviewer, the inspector was informed that'the daletion of these tests are acceptabl _ ~

The inspector will review the startup test program administrative procedures following completion of the licensee actions in the revision of the startup administrative procedures in the next inspectio .3 Initial Fuel Load Procedure Review The inspector held discussions with the Refueling Supervisor and reviewed the following procedure ..

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FP-DMW-IF Refueling, Revision 0, dated January 28, 198 *

P02.01A.08 Core Loading Prerequisites and Periodic Checkout Category 1, Revision 1, dated August 6,198 The procedures were reviewed to verify that licensee commitments were satisfied, appropriate management approval, appropriate committee review, adequate procedure format, appropriate prerequisites and initial conditions, fuel loading steps and increments, count rate periods, use of 1/M plots, verification of assembly positions, appropriate communication, control of Boron concentration, technical specification compliance, nuclear instrumentation operability, and controls for suspension and resumption of fuel handling activitie The licensee's initial fuel loading will be accomplished as a joint effort of Westinghouse and the Duquesne Light Company Refueling Group. The refueling activities are separately and adequately controlled with the procedures reviewed abov Utilizing the two procedures concurrently, the licensee will satisfy the technical specifications associated with fuel loading. The P0 procedure reviewed above has not yet been reviewed by the Onsite Review Committee and approved by the Plant Manager. Prior to this inspection the licensee had instituted activities to assure that all test procedures, such as the Pre-Operational (PO) procedure referenced above, are reviewed and approved in accordance with the technical specifications prior to use. This has yet to be completed for the P0 procedur .4 Startup Test Procedure Review The licensee's Initial Startup Test Program (IST) test procedures listed in Attachment B were reviewed for their conformance to the requirements and guidelines of the references listed in Section and for the following attributes:

Appropriate management review and approval has been accomplishe Appropriate committee review has been accomplishe *

Procedure is in the proper forma * Tes D ec h "a clearly stated and consistent with the FSA Appropriate references are liste .

Appropriate prerequisites and precautions have been include .

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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 pe,rforming the tes The procedure is technically adequate and workabl *

Temporary jumpers, installations and lifted leads are properly restore 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 The test procedures satisfied the attributes except as noted below:

(1) IST-2.04.02 (Shutd:wn from Outside the Control Room): The inspectcr axpressed concerns that the current procedure (Rev. 0)

does not clearly address the situation in the event of loss of communication between the control room and the remote shutdown panel. The licensee representative stated that the control room operators were instructed to take control of the plant in case of any unsafe condition developed during the test. Neverthe-less, to strengthen the procedure, the licensee representative agreed that a more clear instruction would be incorporated in the future procedure revisio (2) IST-2.04.03 (Verification of Plant Performance Following a Turbine Trip Coincident With a Loss of Offsite Power at Load):

The current acceptance criteria are found to be too general and lack specific instructions. As an example, the procedure requires to verify that no adverse conditions occur in the reactor core during the test, however, no specific guidance was provided as a basis for making a determination of acceptabilit The licensee acknowledged the inspector's concern. Due to the complexity of this test, this procedure will be reviewed again in a separate inspection.

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3.0 QA Interface with the Startup Test Program The inspector held discussions with the Supervisor of QA Surveillance and the Supervisor of QA Audit. QA surveillance activities are planned on Startup tests. Witness points have been identified on selected procedures. Procedures are reviewed by QA prior to issuance. QA Audits are planned on the startup test program, one in the initial stages of the program and one at the end of the program. Details of the audits are being developed. QA involvement in the startup program will continue to be assessed in future inspection .0 Exit Meeting An interim exit meeting was held on April 10, 1987 and a final exit meeting was held on April 17, 1987 to discuss the inspection scope and'

findings, as detailed in this report (see paragraph 1.0 for attendees).

At no time was written material given to the license Based on the NRC Region I review of this report and discussions held with the licensee representatives at the exit, it was determined that this report does not contain information subject to 10 CFR 2.790 restriction __

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ATTACHMENT A ADMINISTRATIVE PROCEDURES REVIEWED TPP-12.1, Preparation,' Review, Approval and Revision of Unit 2 Startup Test Procedures, Revision 0 dated April 1, 198 TPP-12.2 Administrative Guidelines for Performing Unit-2 Startup Test, Revision 0 dated April 1, 198 TPP-12.3 Unit 2 Test Records Management System, Revision 0 dated April 1, 198 TPP-12.4 Unit 2 Test Evaluation and Reports, Revision 0 dated April 1, 198 TPP- Testing and Plant Performance Organization, Revision 2 dated April 1, 198 TPP- Testing and Plant Performance Activities, Revision 2 dated April 1, 198 ~

SUM- Joint Test Group, Revision 2 dated June 13, 198 i

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ATTACHMENT B STARTUP TEST PROCEDURES REVIEWED IST-2.018.01 Control Rod Position Indication System Test, Revision 1 IST-2.018.03 Control Rod Drop Time Measurement, Revision 1 IST-2.0lb 04 Rod Control System Test, Revision 0-IST-2.02.0 Initial Approach to Criticality Test, Revision 0 IST-2.02.06 Thermal Power Calorimetric, Revision 1 IST-2.04.02 ' Shutdown from Outside the Control Room, Revision 0 IST-2.04.03 Verification of Plant Performance Following a Turbine Trip Coincident with a Loss of Offsite Power at Load,. Revision 1 PO-2.248-02 Turbine Driven Auxiliary Feedwater Pump Test, Revision 1