IR 05000416/1981056

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IE Insp Rept 50-416/81-56 on 811116-1215.Noncompliance Noted:Failure to Follow Procedure for Testing of Reactor Core Isolation Cooling Preoperational Test & Inadequate Startup Program
ML20042B677
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 01/15/1982
From: Cantrell F, Wagner A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20042B642 List:
References
50-416-81-56, NUDOCS 8203250517
Download: ML20042B677 (7)


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'o UNITED STATES g

NUCLEAR REGULATORY COMMISSION o

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E REGION 11

o 101 MARIETTA ST., N.W., SUITE 3100 k

ATLANTA, GEORGIA 3%03

Report No. 50-416/81-56

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Licensee: Mississippi Power and Light Company Jackson, Mississippi Facility Name: Grand Gulf Docket No. 50-416 License No. CPPR-118 Ir.spector:

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82-Approved by:

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F. 'S. Cantrell, Section Chief, Division of Date Signed Resident and Reactor Project Inspection SUMMARY Inspection on November 16 - December 15, 1981 Areas Inspected This routine announced inspection involved 112 inspector-hours on site in the areas of TMI action plan implementation. reactor water sample, turnover review, system jurisdiction and-tagging, preoperational test schedule review, witnessing maintenance activities, review of QA audits of preoperational testing, plant quality monitoring of pr^ operational testing, fire prevention / protection, plant personnel training, preoperational test witnessing and plant tour.

Results Of the 12 areas inspected, no violations or deviations were identified in 11 areas; 2 items of noncompliance were found in 1 area (failure to follow procedure, paragraph 15.a; and Inadequate Startup Program, paracraph 15.b).

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DETAILS l

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Persons Contacted J

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Licensee Employees

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G. B. -Rogers, Site Manager i

C. L. Stuart, Assistant Plant Manager C. R. Hutchinson, Startup Manager J. C. Roberts, Startup Supervisor -

D. L. Hunt, Plant Quality Supervisor M. Lacy, Field Quality Assurance -

J. W. Yelverton,-Quality Assurance Supervisor i

Other Organizations General Electric M. G. Farschon, G. E. Startup Supervisor

NRC Resident Inspector M. D. Hunt R. L. Fiedler

~* Attended exit interview

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Exit Interv:ew The inspection scope and findings were summarized on December. 16, 1981 with those persons indicated in paragraph _1 above. The licensee had no comments i

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regarding the inspection findings.

3.

Licensee Action on Previous Inspection Findings

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Not inspected.

4.

Unresolved Items Unresolved items were not identified during this inspection.

5.

TMI Task Action Plan Implementation A review was conducted of the procedures implementing the requirements of the TMI Task Action Plan. These requirements are delineated in NUREG 0660 and 0737. The licensee has responded to the NRC by letters AECM 81/387 on

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.i October 12,1981, AECM 81/153 of June 12, 1981 and AECM 81/276 of August 19,

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1981 describing the implementation or providing an implementating procedure for the plan item.

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a.

The following items were reviewed with no comments noted:

1. I.A.I.3 Shif t 11anning

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2. I.C.2 Shift Relief & Turnover Procedures 3. I.C.3 Shift Supervisor Responsibilities 4. I.C.6 Verify Correct Perfonnance of Operating Activities 5. I.A.1.2 Shift Supervisor Administrative Duties b. The following items were reviewed with comments as noted 1. I.A.1.1 Shift Technical Advisor (STA)

There are no implementing procedures available which describe the requirements for on shift STA coverage, qualification requirements for STA's, training requirements or assignment of duties.

2.

I.C.5 Procedures for Feedback of Operating Experience to Plant Staff.

There are no implementing procedures available which include all the concerns identified in NUREG 0737. The MP&L correspondence does not describe the implementation 'of this item.

In addition it is unclear within the itP&L organization who is responsible for its implementation 6.

Reactor Water Sample The inspector witnessed the performance of routine water chemistry sampling on the reactor vessel.

The chemical analy:;is perfonned were witnessed and reviewed for conformance to procedures 08-5-04-104, Revision 2, operation of the conductivity Bridge; 08-5-04-109 Revision, pH (Analysis); 08-5-04-308, Revision 0, Chloride (Analysis); 08-5-04-312, Revision 1, Floride (Analysis); 08-5-04-334, Revision 2, Sulfide (Analysis); 08-5-04-326, Revision 2, Silica (Analysis); 08-5-04-115, Revision 2, Turbidity; and 0-8-5-04-349 Revision 0, Clarity Determination.

The inspector noted that the chemist did not utilize the latest revision of the analysis procedures for determining floride, sulfide and silica.

It was detennined that the changes made by the revised procedure did not effect the analytical outcome.

This item will remain open (416/81-56-01) pending review by the licensee.

The inspector will review the corrective action during a subsequent inspection.

7.

System Turnover Reviews The turnover packages for portions of the Nuclear Boiler System and the Neutron lionitoring System were reviewed for conformance to the requirements

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of Grand Gulf Startup Hanual Chapter 7000, paragraph 4.1.4 and Bechtel Checkout and Turnover Organization Manual Chapter 4, section 16.

No violations or deviations' were. identified.

8.

System Jurisdiction Controls Portions of the Nuclear Boiler System and Neutron Monitoring System were visually spot checked to verify system tagging had been accomplished as required by the Grand Gulf Startup Manual Chapter 5000, paragraph 4.4.

No violations or deviations were identified.

9.

Preoperational Test Schedule Review A review was conducted of the current testing schedule.

The schedule appeared to reflect the current status of testing and the latest project schedule for the completion of testing.

10.

Plant !bintenance Review A review was conducted of various aspects of plant maintenance activities.

The activities selected for review HWO EL-0448 and EL-0481, calibration check of meters and relays. The activities were observed to ensure performance with approved maintenance section procedures 07-5-12-28, 07-5-12-12 and 07-5-12-10.

The qualifications of the maintenance personnel were reviwed for conformance with FSAR 13.2.1.2, Regulatory Guide 1.8, ANSI 18.1-1971 and HPL-lopical-1A.

No violations or deviations were identified in the areas inspected.

11.

Quality Assurance Monitoring The inspector reviewed the. quality assurance monitoring activities in the preoperational test area. The activities were reviewed for conformance with Quality Assurance Procedures !bnual, Chapter 18.20. The following reports were reviewed:

a.

81/84 Standby Liquid Control Test b.

81/84 High Pressure Core Spray Test c.

81/96 CRD Hydraulic Test d.

81/92 Low Pressure Core Spray Test e.

81/73 Test Supervisors Log f.

81/107 Diesel Building HVAC Test

81/109 Nonconformance Control h.

81/117 Suppression Pool Make-up Test 1.

81/118 Load Shedding and Sequencing Test These were several deficiencies noted during the conduct of the monitoring audits.

The documentation of the deficiencies and the corrective actions were contained in the following Corrective Action Reports (CAR's).

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CAR's were reviewed to ensure that corrective actions are in progress or have been taken to present recurrence.

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CAR 326 b.

CAR 327

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CAR 353 d.

CAR 356 e.

CAR 369 f.

CAR 395 g.

CAR'407 m.

CAR 419 No violations or deviations were identified within the areas inspected.

12.

Plant Quality lionitoring A review was conducted of the plant quality monitoring activities in the area of preoperational testing. The activities were reviewed to ensure conformance with Plant Quality Section Procedure 12-5-01-5.

The following reports were reviewed:

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PQt1R 4181 Startup Test Engineer's Log b.

PQt1R 4481 Performance of Preoperational Testing No violatic,ns or deviations were identified within the areas inspected.

13.

Fire Prevention / Protection An inspection of'the control room and elevation 139' of the auxiliary building was made.

The inspection included a review of installed fire protection equipment. The inspector reviewed the records 'for penetrations AE 258B, 174B, 18B, 156B, 1458, 144B and 133B.

The records were reviewed to verify that the penetration sealant material was tested and certified that it is not flammable. There were no fonnal fire protection meetings held since the last inspection of this area.

No violations or deviations were identified within the areas inspected.

14.

Plant Personnel Training

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The inspector attended the Radiation llorker II training course. The course was in two parts, Radiation Protection and Respiratory Protection.

The course was reviewed to ensure that lesson plans were adequate and followed during the course of instruction.

The lessons plans were reviewed to ensure compliance with the administrative procedure implementing managements programmatic requirements.

Two individuals attending the course were interviewed discussing their individual training. Their records were reviewed to verify the correctness of the indicated training reviewed.

There were no comments concerning the lesson plan, presentation or imple-mentation of administrative procedure 01-5-04-10 for the Respiratory

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Protection Program.

It was noted by the inspector that there was not a defined program for providing Radiation Protection training above the minimum training given in the general employee training.

There was not a management approved plan describing a program nor were there any implementing procedures. This item will be designated as open item (416/81-56-01).

It is the inspectors understanding from senior licensee management that this item will be reviewed and appropriate corrective action ta ken.

The inspector will review the corrective actions during a subsequent inspection.

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15. Preoperational Test Witnessing The inspector witnessed the conduct of portions of preoperational test 1251 PT01 Reactor Core Isolation Cooling Preoperational Tr it.

The test was observed for conformance with Grand Gulf Startup Mar :1 Chapter 5000, 7000, Mississippi Power and Light Company Quality Assurance erogram 11PL - Topical-1A and plant administrative procedure 01-5-06-3 Control of System Temporary Al tera tions.

The following observations were made by the inspector.

a.

During the performance of paragraph 7.3.40 testing of a RCIC venti-lation exhaust temperature sensing element and circuit, the test supervisor experienced difficulty in obtaining proper circuit operation.

He then remembered that the channel under test had an incorrect module installed in the circuit.

The test supervisor then directed a maintenance technician to remove the incorrect module and replace it with an appropriate module located in another channel. The technician performed this assigned task without question.

There did not exist a procedural step directing this action. The test supervisor did not process an authorization for modification of a system under test as required by plant administrative procedure 01-5-06-3 Control of System Temporary Alterations and the Startup tianual, Chapter 5000 paragraph 4.12.2.

This is one example of a violation for failure to follow procedures (416/81-56-02).

A review of the test log did not indicate that the test supervisor had taken any actions to ensure testing conditions and/or prerequisites were perfonned prior to restarting the test as required by the Startup fianual, paragraph 4.5.1.5.

This is a second example of a violation for failure to follow procedures (416/81-56-02).

b.

A subsequent review was conducted of the test log to ensure compliance with the Startup/ manual requirements. During this review the inspector noted that at least on two seperate occasions on November 25 and 30, 1981, activities associated with system run-in (SRI) ie; trouble-shooting, correcting system problems, etc. as described in the Startup itanual, Chapter 7000 paragraph 4.2.7.7.3 were performed after the start of the preoperational test.

The Startup Manual in Chapter 5000, paragraph 4.5.4.2, and Chapter 7000 paragraph 4.2.7.2 and 4.2.7.4 implies that the SRI period is prior to the conduct of a test.

It does not specifically prohibit SRI performance after a test has started.

However, the quality assurance program implemented by the Startup fianual does not contain a program to ad*uately document SRI activities

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that may be encountered which are adverse to quality and may invalidate the results of the testing which has been completed.

Failure to-require adequate documentation of conditions adverse to quality constitutes a violation of the accepted quality assurance program and is identified as a violation (416/81-56-03).

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