IR 05000423/1985025

Insp Rept 50-423/85-25 on 850624-27 & 0708-11.No Noncompliance Noted.Major Areas Inspected:Test Witnessing & Procedure Review,Emergency Diesel Generator Status & New Component Identification & QA & QC

ML20134J227
Person / Time
Site:	Millstone
Issue date:	08/16/1985
From:	Eselgroth P, Van Kessel H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20134J211	List: IR 05000423/1985025 ML20134J210
References
50-423-85-25, NUDOCS 8508290215
Download: ML20134J227 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-25 Docket N License N CPPR-113 Category B (

I Licensee: Northeast Nuclear Energy Company -

P. O. Box 270 Hartford, Connecticut 06161 Facility Name: Millstone Nuclear Power Station, Unit 3 Inspection At: Waterford, Connecticut Inspection Conducted: June 24-27, and July 8-11, 1985

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t Inspector A W H. F. Van Kessel, R actor Engineer E-IS~ W date Approved by: h 8' -N- 8[

7. W. Ese 6th, Chief, Test Program date Section RS *

Inspection Summary: Inspection on Jst.e 24-27 and July 8-11, 1985 (Inspection No. 50-423/85-25).

Areas Inspected: Routine, unannounced inspection of the preoperational test

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program including test procedure reviews, test witnessing, Emergency Diesel ( Generators (EDG) status, quality assurance and quality control, and the j identification of new EDG components: The inspection involved 82 hours9.490741e-4 days <br />0.0228 hours <br />1.35582e-4 weeks <br />3.1201e-5 months <br /> on i

site by one NRC region based inspecto Results: No items of non-compliance were identifie l l

l 8508290215 850822 3

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DETAILS Persons Contacted N Northeast Nuclear Energy Company (NNECO)

P. Brown, Startup Engineer J. Chunis, Startup Engineer C. Clement, Maintenance Supervisor E. Fries, Startup Engineer M. Gentry, Assistant Startup Supervisor R. Grebasch, Startup Engineer N. Hulme, Startup Engineer '

S. Jonash, Startup Engineer W. Loweth, Startup Engineer l D. Miller, Jr. , Startup Manager T. Lyons, Startup Engineer D. Scace, Startup Engineer R. Montgomery, Sr., QA Technician J. Short, Assistant Maintenance Supervisor

• S. Sudigala, Assistant Startup Supervisor Northeast Utilities Service Company (NUSCO)

D. Blumenthal, NQA Engineer

• K. Gray, Jr. , NQA Staff Assistant

• L. Nadeau, A. P. Engineer Stone and Webster Engineering Corporation (SWEC)

W. Lamb, Sr. Engineer W. Matejek, Project Advisory Engineer U.S. Nuclear Regulatory Commission (USNRC)

• T. Rebelowski, Senior Resident Inspector

• Denotes presence at exit interview on July 1, 198 . Licensee Actions on Previous Inspection Findings 2.1 (0 pen) Unresolved Item Vibration Induced Valve Failures (423/85-10-01)

Some records on this item were produced by NNECO's maintenance depart-men These records indicate that NUSCO responded to IE Notice 83-70 and its amendment No. 1 (See Inspection report 432/85-10). Further backup documentation will be provided by NNECO. The inspector will review this information during the next inspectio _

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2.2 (0 pen) Unresolved Item, Valve Position Indication Problems (423/85-02-01)

Two generic items have been added by the licensee to the problem matrix, (1) Wrong Description on Control Switch Label (2) Reach Rod Position Indicator Not Installed Item (1) lists only one affected valve but item (2) lists numerous valve For further background on this item refer to inspection

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reports 423/85-10, 24, and 27. The inspector will continue to follow the licensee's corrective actions on this ite . Preoperational Test Program 3.1 Test Procedure Review Scope The test procedures listed in Attachment A were reviewed for adminis-trative and, selectively for technical adequacy and to verify that test planning satisfies regulatory guidance and licensee commitment Discussion Although many of the phase-2 test procedures were available prior to the' test in preliminary or final draft form, the revision 0 of these test procedures was not available to the NRC at the required time be-fore the performance of the test. Since many ESF related tests were scheduled for execution in the near future, the inspector concentrated on the review of these procedures in the second week of this inspection.

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The procedures were examined for management review and approval, pro-cedure format, clarity of stated test objectives, prerequisites, en-vironmental conditions, acceptance criteria and their sources, refer-ences, initial conditions, attainment of test objectives, test per-formance documentation and verification, degree of detail for test instructions, restoration of system to normal after testing, identi-fication of test personnel, evaluation of test data, independent veri-fication of critical steps or parameters, and quality control and as-surance involvement. The inspector had some questions on the fuel oil consumption calculations, and its independent verification, for the EDG-A Licensing Test, T3346AP00 These questions were answered satisfactoril It was noted by the inspector that none of the pro-

. cedures included QC hold points. This is consistent with the QC/QA approach taken by the licensee for the startup program. The licensee relies heavily on in process QA surveillances, performed during the preoperational tests, to achieve quality result . - _ . , _ - _ . . . - . - . .--

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It had been observed in previous reviews of procedures by the inspec-tor that the restoration sections at the end of the procedures tend to be rather general. The licensee explained that they prefer to include restoration steps immediately following the completion of the steps requiring temporary changes to the system. The inspector agreed that this approach would be acceptable but that it may not be followed consistently by all procedure writers. Special attention will be given by the inspector to such restoration steps in future reviews of procedures and, also,-during testin Findings No violations, deviations, or non-compliances were identified by the inspecto .2 Test Witnessing Scope The inspector witnessed selected steps of the following ESF and HFT related tests:

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Charging Letdown and Purification System (T3304AP001)

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Auxiliary Feedwater Pumps (T3322-1M01)

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Diesel Generator B-Mechanical (T3346AP002)

Test Witnessing by the inspector included observation of:

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Overall crew performance

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Use of latest revised and approved procedure, available and in use by test personnel

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Designation of one person in charge of conducting the tests

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Availability of sufficient test personnel to perform the tests

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Coverage of test prerequisites

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Use of acceptance criteria to evaluate test results

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Verification that plant supporting systems are in service

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In-service status of calibrated special test equipment required by the test procedure i

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Adherence to the test requirements of the test procedure during the tests

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Timely and correct actions by test personnel during the per-formance of the tests

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Data collection for final analysis by proper personnel

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The inspector made independent measurements and calculations during the tests including start and stop times and system parameters (see Section 5).

Discussion Test steps following step 7.2.27 of phase 2 test procedure T3304AP001, Rev. O were witnessed by the inspector. The objectives of.this partial test are to verify the proper functioning of the control circuits for valve 3CHS*MV811 The inspector observed the proper functioning of all pertinent instruments on the main control board (MCB) including annunciators 2049 M82E2-6 and 2044MB2ES- Correct responses were obtained from the computer display in the MCB as the test went through the test step The _ inspector witnessed a partial test on the Auxiliary Feedwater Pump 3FWA-1B conducted in accordance with test procedure T3322-1M01, Rev. O. The objective of this test was to determine if the bearing failure problem, experienced on 3FWA-1A pump, would repeat itself on the B pump and also, to determine pump performance in the system as installed. An ultrasonic flow meter (Controlotron, System 480) was installed temporarily to obtain accurate flow measurements. Some problems were experienced in obtaining flow neasurements above 500 gpm. As a result, it was not possible to get the necessary data to verify the full pump test curve as supplied by the vendor. The flow rate data obtained below 500 gpm, however, indicated acceptable agreement with the test curve. The inspector made independent cal-culations to verify the test curve points obtained during the tes The inspector will check on the accuracy of the data obtained with the Controlotron on other tests, in a future inspection. The bearing failure problems of the A pump did not repeat itself on the B pum This bearing failure on the A pump (outboard motor bearing) was diagnosed to be caused by an incorrect coupling gap which forced the bearing against the shaft shoulde The inspector witnessed two attempts to run Emergency Diesel Gene-rator (EDG) B for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without trips or interruptions. Test procedure T3346AP002, Rev. 0 was used for this tes During this test the EDG is subject to the full set of trips provided by the vendor to protect the EDG. Most of these trips are bypassed when the EDG is on regular standby operation to perform its ESF function. The first attempt was started after midnight on July 8, but a trip of

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unknown origin (no first out intelligence available) interrupted the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run. The inspector witnessed the full load dump of step 7.10.8 and checked the recovery for voltage and frequency as indi-cated on the main control board. Recovery was well within the limits of acceptance. The inspector also witnessed the pcrtial load dump of steps 7.11.1.1 to The Turbine Plant Component Cooling Water Pump was used to initiate the partial load dum Frequency response to the load change peaked at 60.4 cycle Recovery was rapid and within the limits of acceptance. A relay (3A) was installed after the trip to obtain a first-out signal on a future trip. The EDG-B was restart-ed on July 9 at approximately 15:00 hours. Another trip was experi-enced in the morning of July 10. This time the trip could be identi-fied via the temporary first out circui It was low jacket water pressure. The inspector discussed this trip event with the respon-sible test engineer. There is a temperature control valve in the jacket water system which adjusts the bypass flow rate on the lube oil cooler to control its outlet temperature. Any such action will cause pressure changes in the jacket water syste Sometimes the pressure transient following valve change is sufficient to cause the low jacket water pressure trip. Vendor approval was pursued for changing the set point sufficiently to avoid the trip on future run Startup Management will insist on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run without any trips prior to the ESF test Findings Test results observed by the inspector indicated that acceptance criteria had been met for those portions of the test that had been witnessed. No items of non-compliance were identifie .3 EDG Status The fuel oil system contamination problems appear to be under con-trol. A program of intensive flushing and cleaning is starting to yield good results as evidenced by the successful runs on EDG-B (see i paragraph 3.2 above). While the two runs witnessed did not complete the desired 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the EDG ran for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without any

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fuel pump or injector failure l l

The inspectors checked on the progress of the dual lube oil filter design effort. Management apparently has decided to proceed with the installation of this desig The inspector observed that the location of the fuel oil filters at the fuel oil pump level (approxi mately nine feet above fl.oor level),

and in proximity to the generators, presents a fire hazard. This j hazard was highlighted by the recently experienced crack in a fuel i

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oil piping tee close to the filte The fuel oozed out of the crack rather than sprayed. A fuel spray could have aimed directly at the open generator enclosure and start a fire or cause an explosion. It is anticipated that both EDGs will be available for the ESF test (with loss of normal power), 3-INT-200 Findings The licensee's corrective action with respect to the fire hazard re-presented by the EDG's fuel oil filter location will be followed by the inspector under Unresolved Item (423/85-25-01).

3.4 ESF Status It is anticipated by startup management that the ESF tests, 3 INT-2003 and 2004 can be started in early August. The items presently on the critical path are the HVAC systems, including SLCRS and Auxiliary Building HVAC (HV9-A), Service Water (T3326-P), and Reactor Plant Component Cooling System (T3330AP). The schedule for these tests is adjusted daily based on the progress of these critical path item . QA/QC Interface Scope Since there are no hold points defined in any of the preoperational test procedures and there is no direct, in process, NUSCO quality control in-volvement, the inspector will closely follow the surveillance program exe-cuted by NUSCO-Q For additional background on NUSCO-QA involvement see inspection report 423/85-0 Discussion The inspector reviewed the NUSCO Quality Assurance Surveillance Reports listed in attachment All of these surveillances are associated with preoperational tests of the Emergency Diesel Generators (EDGs) by request of the inspector. The review indicated good coverage of the tests for the EDG Findings l No violations or non-compliances we e noted in the review of the surveil-l lance report . Independent Inspection and Measurements Scope With reference to Criterion VIII of 10 CFR 50, Appendix B, the inspector ;

pursued the identification and control of the Nugent fuel oil filters of i

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the Emergency Diesel Generator These filters were completely replaced recently, including the filter housing, with filters of a modified desig The objective of this inspection was to verify that the identification of the new filter components was maintained throughout purchasing, storage, and installatio The inspector took independent measu:ements during the Auxiliary Feedwater Pump B test performed in accordance wit.1 procedure T3322-1M01, Rev. Discussion The work order initiating the filter change was identified via the Plant Maintenance Management System (PMMS). The associated record was MRIR 385-085. With help of this MRIR number and the specification number it was possible to retrieve the NNECO purchase order number (901721) assigned to Fairbanks Morse Engineering Division COLT Industries to supply the re-placement filter 3EGF*FLTIB. Shipping papers were then retrieved indicat-ing that some modifications were made to the filter to comply with regula-tory requirement Identification numbers were also found. What remains to be done is to positively identify the modified filter components by individual serial number (on the component) or via the applicable design drawing revision. The inspector will follow this item to completion on a future inspectio Independent readings were taken by the inspector of the inlet and outlet pressure of the Auxiliary Feedwater Pump B during the phase-1 test l (T3522-1M01) as indicated on calibrated test gauges. The inspector com-pared these reading with those recorded by the test engineer and found them to be correct. The inspector also verified the correctness of the TDH (total Differential Head) calculations made by the test engineer through repetition of the calculations. The resulting test points in all cases fell on the manufacturer's test curve (gpm versus feet of water)

Test points for the full length of the curve could not be obtained because

. the Controlotron flow neter, a digital instrument, could not produce l readings above 500 gpm.

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, Proper entries had been made in the PMMS for the replacement of the filters.

l These entries made it possible to retrieve the purchasing documents and to ( identify what was bought and delivered. No violations or non-compliances were identified for the accomplished part of the filter inspection nor for the Auxiliary Feedwater Pump test curve verification efforts.

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6. Technical Specifications (TS) Versus As Built Plant i

The inspector assisted the NRC team, on site during the second week of this inspection, in accomplishing the subject comparison. The inspector will continue to assist this team in the week following this inspection perio l

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r 8 Exit Intervie At the conclusion of the site inspection on July 11, 1985, an exit meeting was conducted with the Licensee's Senior site representatives (denoted in paragraph 1). The findings were. identified and previous inspection items were discusse At no time during.this inspection was written material provided to the licensee by the inspecto l s

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Attachment A Test Procedure Review

• R31 eased for Performance Proc, N Rev. N Date* Title T33015002 0 5-10-85 Reactor Coolant System T3306P 0 2-01-85 Containment Recirc. Spray T33078P002 0 1-17-85 Residual Heat Remova T3308P002 0 1-31-85 High Pressure Safety Inspection T3309P001 0 2-11-85 Quench Spray T3311BA 0 1-14-85 Turbine Plant Sampling T3316AP001 0 4-09-85 Main Steam

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T3319AP 0 3-14-85 Condensate T3324AA 0 7-23-85 Main Generator Protection

, T3330AP 0 1-15-85 RP Component Cooling T3330BA 0 10-04-85 TP Component Cooling-T3331BA 0 9-18-84 Aux. Steam & Condensate System

'T3339AA 0 11-05-84 Chemical Feed-Condensate

T3346AP003 0 10-15-84 EDG-A Licensing Test

, T3346AP004 0 10-15-84 EDG-B Licensing Test T3349P001 0 5-01-85 Plant Computer

- APP.A01 5-01-85 Plant Computer

- APP.801 5-01-85 Plant Computer

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APP.C01 5-01-85 Plant Computer

- APP.001 5-01-85 Plant Computer

- APP.E01 5-01-85 Plant Computer

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- APP.H01 5-01-85 Plant Computer

- APP.IO1 5-01-85 Plant Computer

- APP.J01 5-01-85 Plant Computer

- APP.K01 5-01-85 Plant Computer 31NT2001 0 11-15-83 Computer Programs Test

- APP.3J6 3 INT 2006 0 6-03-84 Turbine Building Hot Func-

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tional Test 3 INT 3000 0 (Draft) Pre-Core Hot Functional Test-APP.3007

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Attachment B Review of NUSCO-QA Surveillance Reports Report N Proc. N Procedure Title or Subject Dis TC-3255 T3405LT01 EDG Loading Safeguards I&C TC-3224 T3346AP002 EDG-B, Mechanical, Phase 2 Mec TC-3268 T3346AP002 EDG-B, Mechanical, Phase 2 Mec TC-3266 T3346A1M04 Diesel Generator Water Cooling Valves Mec TC-3226 T3346AP002 EDG-B, Mechanical - Phase 2 Mec TC-3215 ACP-4.01 Housekeeping (EDG-Bldg)

TC-3112 T3346A1E08 Phase-1 El. Tests EDG Elect TC-3110 T3346A1 Ell Phase-1 El. Tests EDG Elect TC-3109 T3346A1E08 Phase-1 El. Tests EDG Elect TC-3108 T3346A1E09 Phase-1 El. Tests EDG Elect TC-3107 T3346A1E10 Phase-1 El. Tests EDG Elect TC-3106 T3346AIE11 Phase-1 El. Tests EDG Elect TC-3084 T3346A1E09 Phase-1 El. Tests EDG Elect TC-3040 . T3346A1E10 Phase-1 El. Tests EDG Elect TC-3032A T3346A1E10 Phase-1 El. Tests EDG Elect TC-3032 T3346AIE10 Phase-1 El. Tests EDG Elect TC-3031A T3346AIE10 Phase-1 El. Tests EDG Elect TC-3031 T3346A1E10 Phase-1 El. Tests EDG Elect TC-3023 T3346AIE09 Phase-1 El. Tests EDG Elect TC-3016 T3346A1E11 Phase-1 El. Tests EDG Elect TC-2997 T3346A1E11 Phase-1 E1. Tests EDG Elect TC-2978 T3346A1E05 Phase-1 Mech. Tests EDG Mec TC-2951 T3346BIE01 Phase-1 El. Tests EDG Elect TC-2912 T3346B1F01 Phase-1 Mech. Tests EDG Mec TC-2994 T3346BIM02 Phase-1 Mech. Tests EDG Mec TC-2854 T3346A1M02 Phase-1 Mech. Tests EDG Mec TC-2867 T3346A1E01 Phase-1 El. Tests EDG Elect TC-2866 T3346A1IO3 Phase-1 I&C Tests EDG I&C TC-2866 T3346A1IO3 Phase-1 Instr. Test EDG I&C TC-3281 T3405-II01 EDG Loading Sequences I&C TC-3268A T3346AP002 EDG-B, Mech. Phase 2 Test Mech.

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