IR 05000416/1982014

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IE Insp Rept 50-416/82-14 on 820222-26.Noncompliance Noted: Failure to Follow Procedures Following Test Interruptions
ML20052G228
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 03/17/1982
From: Jape F, Andrea Johnson, Matt Thomas
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20052G211 List:
References
50-416-82-14, NUDOCS 8205140427
Download: ML20052G228 (5)


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UNITED STATES l'

NUCLEAR REGULATORY COMMISSION

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101 MA RIETTA ST., N.W., SUITE 3100 ATLANTA,GEORGlA 30303 Report No. 50-416/82-14 Licensee:

Mississippi Power and Light Company P. O. Box 1640 Jackson, MS 39205 Facility Name: Grand Gulf Docket No. 50-416 License No. CPPR-118 Inspection at Grand Gulf site near Port Gibson, MS Inspectors.

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Dade Sihned Engineering Inspection Branch Division of Engineering and Technical Programs SUMMARY Inspection on February 22-26, 1982 Areas Inspected

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This routine, unannounced inspection involved 128 inspector-hours on site in the areas of preoperational test procedure review, preoperational test witnessing, review of outstanding items, and review of plant emergency and operating proce-dures.

Results Of the four areas inspected, no violations or deviations were identified in three areas; one violation was found in one area (failure to follow procedure, para-graph 8).

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REPORT DETAILS 1.

Persons Contacted Licensee Employees

  • C. K. McCoy, Plant Menager
  • T. H. Cloninger, Assistant Site Manager
  • J. W. Yelverton, QA Supervisor
  • J. C. Roberts, Startup Supervisor
  • J. C. Bell, QA Representative
  • M. A. Lacey, QA Representative
  • W. M. Garner, QA Representative Other licensee employees contacted included startup engineers, technicians, operators, electricians, and security force members.

NRC Resident Inspector

  • A. G. Wagner

" Attended exit interview 2.

Exit Interview The inspection scope and findings were summarized on February 26, 1982, with those persons indicated in paragraph I above.

3.

Licensee Action on Previous Inspection Findings Not inspected.

4.

Unresolved Items Unresolved items were not identified during this inspection.

5.

Review of Open Items (Closed) Licensee Identified Item LII 50-416/81-30-02. The licensee closed out Field Report E12-0046 by correcting the electrical schematic drawings to reflect the as built condition concerning certain RHR handswitches on the plant control board. This item is closed.

6.

Preoperational Test Witnessing and Procedure Review The inspectors witnessed portions of the following preoperational tests to verify that the testing was conducted in accordance with approved proce-dures.

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1821PT01 Nuclear Boiler System IC11PT01 Control Rod Drive Hydraulic System IP81PT03 HPCS Diesel Generator Integrated Preop Test 1G41PT01 Fuel Pool Cooling and Cleanup Preoperational Test The inspectors observed overall test personnel performance to verify the following:

a.

An approved procedure of the appropriate revision was available and in use by all test personnel, b.

Special test equipment required by the procedure was calibrated and in service.

c.

Test prerequisites, initial conditions and precautions were met; and those which were waived had been reviewed and approved in accordance with procedural requirements.

d.

Test data was collected and recorded for final analysis by the proper personnel, e.

Deficiencies identifeid during conduct of the tests were properly documented.

Preoperational test procedures for the above tests were reviewed for con-formance with Regulatory Guides 1.68 and 1.108, FSAR Chapter 14, and the implementing section of the Operational Quality Assurance Manual, MP&L-Topical-1. The inspectors verified that management review and approval were indicated, test objectives were clearly stated and acceptance criteria were specified.

7.

Plant Procedure Review A special inspection is being conducted to assure that plant procedures are technically adequate for plant operation.

The inspection encompasses a review of the following procedures:

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Integrated Operating Instructions (101's);

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System Operating Instructions (501's);

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Surveillance Procedures (SP's);

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Off-Normal Event Procedures (ONEP's)

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Emergency Procedures (EP's); and,

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Alarm Respor se Instructions (ARI's).

During the course of this inspection, the inspectors determined, through discussion with licensee representatives, that the plant procedures were not ready for review. The issued and approved 101's, SP's, and ONEP's are

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Revision 0 and according to the licensee, would not be ready for plant operation until at least Revision 10 was approved and issued. These pro-cedures are in various stages of review.

Similarly the majority of 50I's are Revision 0 with final plant-ready-for-operation procedures in various stages of review. The EP's are considered to be in final form, however the licensee is still negotiating changes with the Nuclear Steam System Supplier (NSSS). Following disposition of these changes, final EP's will be issued.

During this inspection the inspectors toured the plant, reviewed plant drawings, and read select plant procedures. One S0I, 04-1-01-L11-1, Plant DC Systems, Revision 10, was reviewed in detail since this procedure was the one 501 that the licensee stated was in the final form.

The licensee has established a program for procedure revision that includes a walk-down of as-built systems and " red-line" mark-up of procedures as they have been utilized. These walk-down and red-line results will be incorpor-ated in the final procedure form.

Based upon the review of SOI 04-1-01-L11-1 and the reading of selected procedures, this program appears to be effective in assuring that procedures are technically adequate for plant operation.

The licensee has stated that safety-related procedures will be approved and issued in their final form by April 5, 1982.

The effectiveness of the licensee's procedure revision program will be examined during a review of the final form procedures on a subsequent NRC inspection.

8.

Preoperation Test Performance The inspector observed that during the period of February 23 and 24,1982 (during the performance of the offical HPCS preoperation test) the test supervisor had two test interruptions as defined in the startup manual. The first test interruption was icgged in by the test supervisor in his official log, but he failed to fill out the retest control form. The second test interruption was not logged nor was the retest control form completed as required by the startup manual as stated below.

The above is contrary to 10 CFR 50, Appendix B, Criterion V.

The Opera-tional Quality Assurance Manual, MP&L-Topical-1, paragraph 5.4.1 requires

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activities affecting quality be performed in accordance with documented I

instructions, procedures or drawings.

Grand Gulf Startup Manual, Section SUM 5000, paragraph 4.1.4.3 states that "When a step or section of the test i

cannot be completed, or when results obtained are not within the stated acceptance criteria, an Exception Sheet, Startup Form 5.2 (Appendix B),

l shall be completed, in accordance with this procedure, to document the l

problem except as noted in 4.2.7.7 of SUM 7000. Testing may continue when l

the criteria of Exception Sheet usage are met."

Step 4.2.7.7 of SUM 7000 states that.

"There may be occasions when it is not possible to continue a i

test due to various plant conditions or due to technical or procedural t

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problems. Should this occur, the Test Supervisor must carefully consider what action to take, since invalidating preceding or subsequent test data or subsequent test steps may result." Options are as follows:

a)

If a step or series of steps can be deferred such that the test can be continued without invalidating subsequent test step (i.e.,

skip a computer point), the Test Supervisor shall execute a TEST EXCEPTION in accordance with SUM 5000 section 4.1.5.2.

b)

If a change of the procedure is required to permit continuation of testing, the Test Supervisor shall execute a TEST CHANGE NOTICE (TCN)

in accordance with SUM 5000 section 4.1.5.1.

c)

If it is necessary to perform TIPE (Test Interruption for Problem Evaluation) activities as described in 4.2.7.4 such as troubleshooting and/or corrections, the Test Supervisor shall execute a Retest Control Form, in accordance with SUM 5000 section.

Following turnover of a system to Startup. A Retest Control Form Log Book must be initiated and maintained by Cognizant Test Supervisor.

The Log consists of the system Retest Control Forms (Startup Form 5.19, Appendix I) and the system Retest Control Form Log sheets (Startup Form i

5.20, Appendix M).

When an official test, or portion of a test, being performed is interrupted due to problems, subsequent activities by the Test Supervisor to identify the problem are termed Test Interruption for Problem Evaluation (TIPE)

activities.

These activities consist primarily of troubleshooting and performing trial runs. The activities are performed under an approved MWO, per requirements of Maintenance Section Procedure 07-S-01-6.

In general a single MWO per discipline will cover the entire scope of TIPE activities on a system.

Control of the test, however, was maintained by the test supervisor.

Therefore, this item is classified as a severity level VI, violation (50-416/82-14).