IR 05000425/1989008

Insp Rept 50-425/89-08 on 890123-27.No Violations or Deviations Noted.Major Areas Inspected:Preoperational Testing,Preoperational Test Results Evaluation & Followup on NRC Bulletins 88-004 & 81-02

ML20247D372
Person / Time
Site:	Vogtle
Issue date:	02/28/1989
From:	Belisle G, Szczepaniec A, John Zeiler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20247D369	List: IR 05000425/1989008 ML20247D366
References
50-425-89-08, 50-425-89-8, IEB-81-02, IEB-81-2, IEB-88-004, IEB-88-4, NUDOCS 8903310057
Download: ML20247D372 (8)

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NUCLEAR REGULATORY COMMISSION

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~ 101 MARIETTA ST., ,

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sReport No.: 50-425/89-08 Licensee:- Georgia Power Company P. 0. Box 1295 Birmingham,'AL 35201 Docket No.: 50-425 License No.: NPF.79

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Facility Name: ' Vogtle 2

Inspection. Conducted: January 23-27, 1989-Inspectors:

A. Szczepaniec Mb /

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Ddte Signed

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N h '2 f J..Zeiler 7 / Date Signed-

Approved by: 6c W M I W '

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George. A.: Belisle(Chief 4

'V Dite Signed Test Programs Section Engineering Branch-Division of Reactor. Safety SUMMARY

' Scope This routine, announced inspection was in the areas of.preoperational testing; preoperational'. test results evaluation; Readiness Review Module -03A, Phase 3;

' follow-up on NRC Bulletins 88-04 and 81-02; and licensee action on previous inspection finding ,

Results The preoperational test results review indicated that the ifcensee is perform-ing an adequate test results evaluation. Test data was found to be within-established acceptance criteria. The licensee's methods for correcting test deficiencies were found- to be acceptable. Management . was involved --in the preoperational test results review process as evidenced by the thorough and detailed reviews being conducted. Management was also involved in the overall preoperational test program as evidenced by establishing a " mode" prioritized work order tracking system. This system will be used to track and prioritize outstanding work to determine progress toward completing preoperational testing and startup testin No violations or deviations were identifie B903310057 890303

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REPORT DETAILS Persons' Contacted Licensee Employees

• G. Frederick, QA Site Manager, Operations

• Gabbard, Senior Regulatory Specialist

• T. Greene, Plant Support Manager

• S. Hall, Procedure Superintendent

• C. Hayes, Vogtle Quality Assurance Manager  ;

• C, Miller, Jr., Engineering Support Superintendent

• Nicklin, Compliance Supervisor

• J. Swartzwelder, Manager NSAC Other licensee employees contacted during this inspection included engineers, technicians, and administrative personne Other Organization

• P. Trnavsky, Mechanical Engineer, Westinghouse

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NRC Resident Inspectors

• R. Aiello, Resident Inspector

• C. Burger, Senior Resident Inspector - Construction

• J. Rogge', Senior Resident Inspector - Operations

• Attended exit interview Preoperational Testing Preoperational Test Procedure Results Review Evaluation (70311, 70322,70325,70326,70541,70534,70400)

The inspectors reviewed the results of the following procedures:

2-300-01, Integrated Safeguards and Load Sequencing Test, Rev. I 2-3SB-01, Reactor Protection, Rev. 0 2-3SB-02, Reactor Protection Safeguards Test, Rev. O  ;

2-3KJ-06, Diesel Generator Train "B" Synchronization, Load Rejection, i 5 Air Starts and 35 Consecutive Starts, Rev. These test procedures were reviewed to verify that the technical  !

content was consistent with the Final Safety Analysis Report (FSAR)  !

and Regulatory Guide (RG) 1.68 requirement In addition, the test procedures were reviewed to verify the following:

- Test changes were annotated appropriately and approved in accordance with administrative procedure _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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- -Test changes did not. affect the_ basic test objective ' Data' sheets were completed and the _ data that recorded wer ;within specified acceptance criteri '

- TestL steps and data _ sheets were ' initialized and, dated as require Quality ' Control hold points were properly signed and dated _ as

- requi re Test deficiencies were resolved including retesting, where require Management had evaluated the test results as required by administrative control In general, the review by the licensee Test Review Board 1(TRB) was

.found to be acceptable for those proce dures rev iewed. The approval process was also reviewed and was found to be.in accordance with the

? licensee's Startup Manual'(SUM). The reviewer's comments indicated a

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thorough understanding of ~the administrative and regulatory require-ments, technical content, and test methods ' within the: applicable-procedure In only one case was a change processed as a minor change 1when it should have_ been a major change', requiring .TRB approval. In-that change, one subsection was deleted from procedure 2-3SB-01; however, the change was a direct result of a TRB commen Since the TRB was aware of the change, and subsequently approved the

- procedure results, it was obvious the TRB did essentially approve its affect on the procedure. This is acceptable to the inspector and no further. licensee action'is require During test ' data review, it was noticed that diesel generator voltage obtained in Preoperational Test 2-300-01 exceeded acceptance criteri However, 'the obtained data was appropriately reviewed, justified and documented by the TRB to be acceptable. This is authorized by SUM procedure A temporary modification was also found to have been installed while performing procedure 2-300-01. However, the modification was appropriately accounted for, documented, and justified by the TRB, in accordance with the SUM requirements. This modification was found to be acceptable since it had not affected the test result The modification was later removed and the circuit was checked for proper operatio The modification involved temporary wiring to a light indicator, which was easily checked, and did not affect the circuitry or logic main functio Violations or deviations were not identified in the review of this program area.

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b .- Readiness Review, Module 03A, Phase 3 Module 03A, Initial Test Program, Phase 3, Preoperational Test Phase, for Vogtle Unit 2 Readiness Review was submitted with an effective date of November 1, 1988. This module phase further assesses imple-menting test procedures and reviewing and approving test result he updated copy of Module 03A which was reviewed included a second revision to Phase 1 and also contains follow-ups to Phase 1 and Phase 2 corrective actions. The assessment also included observing test performances, verifying test personnel certifications, and controlling design changes. Phase 3 is the final phase of the initial test program three-phase revie The licensee's assessment of their program appears to be adequate for reviewing' test procedures and test results. Nuclear Regulatory Commission (NRC) findings of test procedure review, test witnessing, test result evaluations, and test result packages are documented in this and previous NRC Inspection Report Nos. 50-425/88-76, 88-73, L 88-69, 88-66, 88-65, 88-60, 88-57, and applicable resident inspector report Phase 1 and Phase 2 acceptance is discussed in NRC Inspection Report Nos. 50-425/88-15 and 50-425/88-55, respectivel Reviewing the licensee's readiness review audits and findings concluded that the responses and corrective actions appear to be adequate and acceptabl Two preoperational test period items identified earlier by the NRC that remain open are Inspector Followup Item (IFI) 425/88-73-04, Review Resolution of Blind Flange Local Leak Rated Tests, and Unresolved Item (UNR) 425/88-73-05, Review Purge Valve Lccal Leak Rate Testing to Ensure That a Conservative Test is Performed. During this inspection, both items were found to be awaiting final resolution by the licensee. The licensee has committed to resolve these items before fuel loadin One other item noticed by the inspector was that even though the Phase 3 readiness review included hot functional testing, it did not identify that a test, requiring those conditions, had failed and would have to be reperforme Licensee manageaent requested deferring the test reperformance until initial startup, l when required plant conditions would be re-established. If it was  :

known that the acceptance criteria was not met before completing !

hot functional testing and it was anticipated that no other opportunity would be made available befora startup, this item should have been addressed in Phase Since the deferred test has been approved by NRC and has been scheduled by the licensee, no further action regarding readiness review is require :

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l, With the identification' of :the Ideferred testing,- and 'with the excep-m: tion of the two ' open Litems' ment 1oned previously, and as a result'

- of the' review of the readiness review submittals a$d the' ongoing NRC; review of selected procedures, the licensee's submittal for Phase 3 of Module 03A .is found to be acceptable in that 'it appears the

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licensee ;has implemented adequate programs and procedures which meet the commitments identified in the commitment inde The openiitems will be_ reviewed during' a future. inspectio Violations 'or . deviations were not identified 'during the : review of

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Readiness Review, Module 03A Phase independent. Inspection (92706)

A' review of outstanding ' work and.the method used by the ' licensee to

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track. and prioritize work was niade - tot determine progress - toward

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completing -. preoperational testing and' proceeding into' startup testin It was observed that two systems are being used to ensure required work is -completed prior to startup-testing and -subsequent operatio One ' system 'is construction oriented and utilizes the licensee'

Master Tracking. System -(MTS). In this system the licensee itemizes-workiorders and other non-work documents. The work documents. are

.themselves . categorized by mode- constraints , that is, the system identifies which work -is required to be! completed to support .the

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J-six modes off operations which range from fueling to power operation The: licensee began this categorization. in early January and has.been progressively reducing the number of outstanding item The:second method is that. outstanding work, required to be completed

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L to; support the various . modes, is tracked by the Operations Department. . Although this uses work ' items identified on the MTS, it relies. on identification of outstanding work items by licensed ,

operations personnel as being Limiting Conditions for Operatio i Therefore the Operations Department is asst red that all necessary work is completed before changing modes.of operatio ji

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i Although non-work documents on the MTS are not categorized by mode I constraints, licensee personnel have stated that they have been !

considered and none have been identified as being mode dependen ;

Work orders associated with the non-work documents are being tracke .L_______._._._.___

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The methods used by the licensee appears acceptable and adequately manage Violations or deviations were not identified during this revie ,

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3. NRC Bulletin Follow-up (92703) I NRC Bulletin 88-04 Follow-up (Closed) 50-424, 425/88-BU-04, " Potential Safety-Related Pump Loss."

This bulletin requested all licensees to investigate and correct, as applicable, two miniflow design concerns. The first concern involved the potential for dead-heading one or more pumps in safety-related systems that have a miniflow line common to two or more pumps or other piping configurations that do not preclude pump-to-pump inter-action during miniflow operation. The second concern is whether or not the installed miniflow capacity is adequate for even a single pump.in operatio By letters dated July 11 and October 25, 1988, Georgia Power Company responded to all bulletin action items except for Action Item 3 as it applies to the Auxiliary Feedwater pumps. In a previous NRC inspec-tion (Inspection Report Nos. 50-424/88-51 and 50-425/88-66), the licensee's responses and Westinghouse evaluations were reviewed and found acceptable except for the Residual Heat Removal (RHR) pump evaluatio The licensee's evaluation stated that dead-heading the two RHR pumps would not occur and one of the factors that this conclusion was based on was that the check valves in the RHR suction lines are not leaking excessively back to the Refueling Water Storage Tank (RWST). In the previous inspection, the inspector questioned the licensee if any surveillance tests were performed to verify the operability of the suction check valves. The issue was not resolved during this earlier inspectio !

The inspector followed up on the RHR issue by reviewing Vogtle  !

Operating Procedure 14805-1, " Residual Heat Removal Pump and Check Valve IST." The purpose of this procedure is to demonstrate the operability of the RHR pump and the pump's suction and discharge ,

check valve Check valve operability is verified by observing  !

pressure indications from pump discharge and RWST levels during RHR {

pump flowrate tests. The procedure states that if pressure on the j l RHR train being tested remains constant and if the RWST level is i stable, then the suction check valve has seate The frequency of this surveillance procedure is at least once every three month The inspector had no further concerns in this are By letter dated December 15, 1988, Georgia Power Company provided the response to Action Item 3 to the bulletin concerning the Auxiliary Feedwater pump evaluatio The inspector reviewed this response and considers it to meet the requirements of Bulletin 88-04, Action  :

Item 3. This bulletin is considered closed.

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. 6 NRC Bulletin, and Supplement 81-02. Follow-up- (0 pen) '50-424, 425/81-BU-02, " Failure of Gated Type Valves to 'Close Against Differential Pressure."

This bulletin and supplement requested all licensees to verify the presence or absence of Westinghouse Electro-Mechanical Division (W-EMD) manufactured motor-operated gate valves and verify their ability to close under the current and/or intended service condi-tions. The entire line of. W-EMD manufactured motor-operated gate t

valves had . the potential for not closing against differential pressur The inspector reviewed licensee's responses to the bulletin dated April 21, July 2, and November 20, 198 Modifications were specified for 3-inch and 4-inch gate valves in the April 21. and July 2, 1981 letter The inspector then reviewed Field Equipment Change Orders (FECOs) which documented corrective actions performed on these gate valves. The inspector.found that in some cases, the corrective action performed was not the same as that specified in the licensee's initial respons When the licensee was questioned.about this matter, the inspector was told that Westinghouse Corporation would have to be consulted concerning these differences, since Westinghouse performed the valve evaluations and prescribed the valve modifications. The inspector also asked if the licensee had documentation regarding the final disposition, i.e., how the gate valves were finally modified to ensure that they were qualified for the intended service. The licensee was unsure if such documentation existe This matter was discussed with the licensee at the exit meeting where the licensee was informed that the bulletin will remain open pending further NRC revie . Inspector Follow-up (92701) (Closed) Construction Deficiency Report (CDR)-M-134, Solid State Protection System Relay The short term corrective action, which was previously reviewed and found acceptable, was assessed by the licensee as a possible long term fix. The assessment concluded that a different modification to the circuitry was required to ensure the original deficiency would not recur. The long-term fix was installation of a Resistor / Capacitor (RC) network in all the affected circuits; the short-term fix was left, if already installed, as it does not affect the proper operation of the RC network. The assessment, design, and modifications to the appropriate drawings were reviewed and found to be acceptable. The modified circuits were tested during Preoperational Test 2-300-01, Integrated Safeguards and Load Sequencing Test. Relay problems were not identified as a result of the testin This item is considered close !

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b.- (Closed) 'CDR-M-149,' Valcor Containment- Isolation Valves. ,

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Six valcor . valves had been idehtified by .the licensee as.having been

installed in the wrong directio The assessment'and corrective action by : the ' licensee for: the . identified valves were reviewed -

~ and found to be acceptable. Valve leak rate testing and the

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applicability of ; the findings - to the ' other- containment - valves will be. reviewed;by the NRC during the evaluation of the . leak rat preoperational . test result . Exit Interview The inspection scope and results were summarized on January 27, 1989 withi those persons .._ indicated in paragraph 1. - The inspectors described the areas inspected and , discussed in detail . the~ inspection result Dissenting comments were not received from the licensee.-

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