IR 05000440/1985063
| ML20209H601 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/05/1985 |
| From: | Dave Hills, Odwyer G, Rescheske P, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20209H574 | List: |
| References | |
| 50-440-85-63, NUDOCS 8511110177 | |
| Download: ML20209H601 (11) | |
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- U.S.-l NUCLEAR REGULATORY COMISSION
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REGION.III
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J Report No.--50-440/85063(DRS)-
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Docket No. 50-440 :
License No. CPPR-148
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Licensee:- Cleveland Electric Illuminating Company-
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-Post Office Box 5000 Cleveland,L0hio 44101-Facility Name:
Perry Nuclear Power Plant, Unit-1 Inspection Ati Perry Site, Perry, Ohio-
.In'spection. Conducted:
September 14.through October 18, 1985 jgo R
. Inspectors:
G. F._0'Dwyer
3f Dath-]
.d. e. N2?L D. E. Hills-Date P
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Date
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Approved By:
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Test: Programs Section Date '
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Inspection Summary
-Inspection on September 14 through October 18, 1985-(Report No. 50-440/85063(DRS))
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-Areas Inspected:
Routine, announced inspection of previous inspection findings, preoperational. test procedure verification, preoperational test procedure review, preoperational test witnessing, preoperational test results verification,
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preoperational test results review, preoperational test program implementation, and startup test procedure review. The' int,pection involved a total of 90
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. inspector-hours onsite by 3 inspectors including 9 inspector-hours during off-shifts.
In addition, there were 168 inspector-hours spent offsite.
' Results: Of the eight areas inspected, no violations or deviations were identified.
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. DETAILS n
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.Pe'rsons Co'ntacted
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- C.-M.:Shuster,^ Manager, Nuclear Quality Assurance Department-
- . J.tJ. Waldron, Manager, Perry Plant Technical Department
'*G.;R.Kleidich,' General-Supervising Engineer, Nuclear Test Section
.*G..H. 'Gerber, Element: Supervisor Administration, Nuclear Test Section
- J. G. Cantlin,10perations Engineer (Startup Test Engineering Lead),
Perry Plant Technical Department
- . B. B.'.Liddell, Operations Engineer, Perry Plant Technical Department
- N. J.!Lehman,: Staff Ana.lyst, Perry Plant Technical Department
- L. B. Biddlecome,. Senior Staff Engineer--
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- T.-G.'Swansiger, Supervisor, Operational Quality.Section.
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- F. H. Songderoth, Senior Engineer-
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The inspector also interviewed other licensee employees including members of the quality assurance, technical, operating, and testing staff.
- Denotes persons attending 'the exit meeting of October 18, 1985.
' 2.
Licensee Action on Previous Inspection Items a.-
.(Closed) Unresolved Item (440/85013-05(DRS)):. Resolution of
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questions / comments generated during review of preoperational test
. procedure TP OM40-P001, " Fuel Handling Area Ventilation System,"
Revision 1.
The inspector. verified that these comments have been adequately. addressed and resolved. The inspector has no further concerns in this area.
b.
(0 pen) Unresolved Item (440/85002-02(DRS)):
Consideration of instrument inaccuracy in determination of preoperational test procedure acceptance criteria.~ The licensee developed a Special Project Plan 0301, " Coordination of Setpoints and Interrelated Documents," to address this item.in addition.to several related issues.
This plan established a review team to investigate various problem areas including test acceptance criteria versus instrument inaccuracy. A final report of these efforts has been issued which indicates that in many cases, except-for those values given in General Electric (GE) test specifications and their associated documents,-test equipment accuracy was not considered with regard to preoperational test acceptance criteria.
Thus, decision charts were developed to be used in reviewing acceptance criteria against
'preoperational test results and test equipment accuracy to determine acceptability and appropriate actions.
This additional review effort has been initiated by the Nuclear Test Section for all quantitative data except for that prescribed by the GE test
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. specifications and related documents which is recorded from GE supplied / designed equipment and instrumentation.
GE has indicated that the basis for.this acceptance criteria is conservative to account for instrument inaccuracies.
All quantitative acceptance criteria is to be examined and, where applicable, instrument inaccuracy, for either permanent plant instrumentation or measuring and test equipment, will be used to adjust the results.
In cases where this causes the measured values to exceed the acceptance criterion tolerance, appropriate action is to be taken including engineering evaluation and retest if necessary.
The licensee indicates that at the end of these efforts a summary report will
'be issued.
c.
(Closed) Unresolved Item (440/85005-01(DRS)):
Resolution of questions / comments generated during review of TP OM25/26-P001,
" Control Room "VAC and Emergency Recirculation System," Revision 1.
The majority of these comments were upgraded to examples of a violation in Inspection Report 440/85013(DRS).
The inspector reviewed the remaining comments and verified that they have been adequetely addressed and resolved.
Tha inspector has-no further concerns in this area.
d.
(Closed) Violation (440/85013-01(ORS)):
Preoperational test procedures TP OM25/26-P001, " Control Room HVAC and Emergency Recirculation System," Revision 1, TP 1M98-P001, " Supplementary Charcoal and HEPA Filters Efficiency Test," Revision 0, and GEN-M-016, " Test Balancing (Air)," Revision 6, determined to be inadequate.
Additional examples, TP 1833-P002, " Recirculation Flow Control Valves," Revision 1 and 1E12-P001, " Residual Heat Removal System," Revision 1, were identified in inspection report 440/85017(DRS).
As described in inspection report 440/85042(DRS),
the inspector verified that problems have been corrected for these two additional examples.
In addition, this same report also identified TP 1C41A-P001, " Standby Liquid Control System,"
Revision 0, as an additional example. The inspector has now verified that the identified problems with TP OM25/26-P001,
'TP 1M98-P001, GEN-M-016 and TP 1C41A-P001 have been corrected by incorporation of changes in procedure revisions.
The effectiveness of licensee corrective actions to ensure adequacy of preoperational test procedures will be tracked by previous inspection item 440/85053-01(DRS).
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(Closed) Violation (440/85042-01(DRS)):
Preoperational test procedures TP 1C71-P001, " Reactor Protection System," Revision 1, TP 1C71-P002, " Reactor Protection System Motor Generator Sets,"
Revision 0, TP 1M51-P001, " Combustible Gas Control System,"
Revision 0, determined to be inadequate.
The inspector verified that the identified problems have been corrected by incorporation of changes in procedure revisions and test change forms.
The effectiveness of licensee corrective actions to ensure adequacy of preoperational test procedures will be tracked by previous inspection item 440/85053-01(DRS).
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(Closed) Open Item (440/85042-05(DRS)):
Preoperational test procedure TP 1M51-P001, " Combustible Gas Control System,"
Revision 0, to be revised to make it consistent with technical-specification surveillance requirements.
The inspector reviewed Revision 1 to this procedure and verified that the indicated additional testing has been incorporated.
The inspector has no further concerns in this area.
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(Closed) Open Item (440/85042-02(DRS)):
Licensee to provide Initial Checkout and Run-in test procedures for reactor protection system response time testing.
The licensee has provided these procedures which the inspector has reviewed and found to be adequate.
The inspector has no further concerns in this areas.
h.
(Closed) Violation (440/85042-06(DRS)):
Inadequate measures to indicate the status of equipment in the control room.
The inspector verified that Test Program Instruction (TPI)-9, " Turnover to the Nuclear Test Section (NTS)," has been revised to require that all control devices under NTS jurisdiction in the control room be tagged or identified with a dot (except for indication instruments).
The inspector physically verified the implementation of this requirement by observing blue tags and dots on appropriate equipment in the control room.
The inspector also reviewed training records to ensure appropriate personnel have been trained to this revised requirement.
The inspector has no further concerns in this area, i.
(Closed) Violation (440/85042-07(DRS)):
Inadequate measures to ensure that the System Test Engineer (STE) is aware of the status of his system with respect to temporary. alterations while undergoing testing.
The licensee conducted a review to determine the extent that the identified ambiguities of TPI-18, " Temporary Alterations,"
Section 4.1.1 and 4.1.2 affected the test program.
The inspector examined documentation of the results of this review which compared the System Test Engineer (STE) memoranda against the Release for Test (RFT) dates.
The purpose of this memoranda is to provide t e STE with the option of controlling temporary alterations on his system prior to RFT.
The review showed that all but one STE had submitted the memorandum prior to the RFT date.
For the remaining system, another RFT had been conducted following cancellation of the original performance and a revision of the procedure. Therefore, the actual effect upon test performance appears to have been minimal.
As mentioned in Inspection Report 440/85042(DRS) the licensee has issued Revision 4 of TPI-18 which transferred control of the implementation of all new temporary alterations to PAP-1402,
" Control of Lifted Leads, Jumpers, Temporary Electrical Devices and Mechanical Foreign Items." Test Change Notice (TCN)-005 to this procedure was issued to require the STE's concurrence to temporary alterations.
In addition, Section 4.1 of TPI-18 has been revised to require STE review and approval for removal of temporary alterations under Nuclear Test Section (NTS) control.
This revision is consistent with PAP-1402.
Furthermore, the inspector verified that applicable portions of TPI-25, " Initial Checkout and Run-in
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L Cond'uct of : Testing,'!.and TPI-28,;" Conduct of Preoperational,
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"Special and Acceptance Tests," have-been revised to assure that
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the Test" Coordinator'is' cognizant of all temporary alterations'
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! implemented or removed per approved Nuclear-Test Section (NTS) test
. procedures.1This allows the Test' Coordinator to take appropriate
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Lactions if there is any impact on current testing activities eThe c
~ inspector alsoLverified that additional training has been.given to appropriateLpersonnel concerning these administrative changes.
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. inspector has-no further concerns in this area.
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- (Closed)' Unresolved Item-(440/85042-04(DRS)):
Inspector to review-changes to testing of combustible gas control system compressors..
- The inspector has. completed this review to ensure conformance with
> regulatory requirements and.has no_further concerns-in this area.
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(Closed);0 pen _ Item (440/85053-02(DRS))!
Licensee to correct FSAR 1 discrepancies regarding safety-related instrument ~ air.
The inspector has reviewed Change Requests Nos. 448,_471, and 521 to ensure that.they: address the indicated discrepancies and have
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1been-approved by the-licensee staffz for. submittal to the Office of
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Nuclear. Reactor Regulationi(NRR)'for incorporation into the FSAR.
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L(Closed) Open It'em (440/85022-41(DRS)):
SER Confirmatory Issue 26 to verify that the anticipated transient without scram recirculation pump trip is. tested.
The inspector reviewed applicable portions of TP 1C22-P001, " Redundant Reactivity Control System," test results-i to ensure.that the' recirculation pump trip portion of this system l
lhadbeentested. The inspector has no further concerns in this
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3.
Preoperational Test Procedure Verification The inspector verified that the following preoperatior al test procedures
.were prepared, reviewed, and approved in accordance with the requirements
.of Regulatory Guide 1.68, the Test Program Manual (TPM),.the Final Safety
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Analysis Report (FSAR), the Safety Evaluati_on Report ~(SER)~and the
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= Quality: Assurance (QA) Program and found them satisfactory except'as
'noted below:
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TP 1N32-A001, " Turbine Control EHC," Revision 0
'TP.IN64-A001, "Off gas Charcoal Vault Refrigeration," Revision 0 TP 2M42-A001, " Turbine Power Complex Ventilation," Revision 0 TP IG60-A001, " Miscellaneous Sump System,'? Revision 0 TP 1R61-A001,' " Main Control Room Annunciator System," Revision 1 TP 1R10-A001,'" Normal AC Power Distribution System," Revision 0 TP 1PS2-A002, " Loss of Instrument Air," Revision 0 TP 1N27-A001, "Feedwater System,". Revision 0
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'TP 1M14-A001, " Containment Vessel and Drywell Purge," Revision 1
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- TP IC85-A001, " Steam Bypass and Pressure Regulation System," Revision 0
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.TP 0P84-A001, "Hypochlorite Generation, Cooling Tower Feed and Plant
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Discharge Dechlorination System," Revision 0
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Preoperational Test Procedure Review The-inspector reviewed'the following approved test procedures against the FSAR, the SER, Regulatory Guide 1.68, QA Manual, Test Program Manual, applicable Regulatory Guides and American National Standards Institute (ANSI) Standards and docketed correspondence and found them satisfactory Texcept as noted below:
a.
' TP 1821C-P001, " Nuclear Boiler:
Nuclear Steam Supply Shutoff System," Revision 0 b.
TP 1R76-P001, " Emergency Core Cooling System Initiation / Loss of Offsite Power," Revision 1 c.
TP 1E53-P001, " Containment Isolation System," Revision 1 FSAR Section 6.2.4.1 indicates that "after initiation of containment isolation, either automatically or manually, the function goes to completion." Upon review of this test procedure, the inspector did not note any testing of the valve logic which verifies this design function..However, this testing may have been included in other related testing procedures.
This is considered to be an unresolved item until the inspector has reviewed and determined the extent to which this logic has been tested in other nrocedures (440/85063-01(DRS)).
No violations or deviations were identified; however, a portion of this program. area requires further review and is considered an unresolved item.
5.
Preoperational Test Witnessing The inspector witnessed the following preoperational tests to ascertain through observation and review of documentation that testing was conducted-in accordance with approved procedures and that test results
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Additionally, the performance of licensee personnel was evaluated
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during the test.
These were found to be satisfactory, a.
TP 1C71A-P001, " Reactor Protection System," Revision 2.
The inspector witnessed portions of step 6.38, in particular the preparation.for testing the response time of the turbine control valve fast closure scram signal.
The testing was temporarily terminated because of a larger loss of condenser vacuum than was expected by the operators when the turbine control valves (TCV)
were opened. The operators had expected a pressure drop because
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openingthhTCVs-increases 1thevolumeon'whichavacuum.is
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drawn by the extent of_ piping from the Turbine Control Valves
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.TP 1821C-P001,'" Main Steam Isolation Valve (MSIV) Iso'1ation Logic,"
Revision 0._ The! inspector witnessed portions of this test. On step 6.25.16 when the MSIV solenoid was deenergized the pilot-solenoid current 'ight on panel.H13-P623 (the DIV-I AUX relay
- panel) did not'de energize.as expected. The STE stopped testing Land-documented the'?ailure with a test exception.
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-TP.1E22-P001, "High; Pressure Core Spray (HPCS) System," Revision 1.'
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- The' inspector witnessed test addendum No. 1, steps 6.13.1.k through-
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6.13.21 consisting of manual-initiation of the HPCS-bus normal supply breaker.
The HPCS-diesel generator is. to be verifieci to start'and pick upiloads and the HPCS system is to be verified to
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reach rated flow within prescribed time limits.
However, following
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1 initiation in' test step 6.13.20, the HPCS Injection Valve 1E22-F004 failed.to open'.. The remainder of the HPCS-system functioned
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This failure was-attributed to the reactor vessel high
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1 water level relay K13 remaining energized which prevented ',alve
.:1E22-F004 from opening.
Previously, step 6.13.1.j had been performed which prescribed pulling fuse F12 in the circuitry to Ldisable3 nterrupting. relay signals including reactor vessel high i
water level.
However, this action failed-to de energize the K13
" relay because the seal-in-logic was already energized prior to pulling _the fuse.
The circuitry containing the reactor vessel high water level seal-in bypasses fuse _F12.
A test change was therefore written to depress,the high water level reset-pushbutton prior to-initiation'and the test was successfully repeated in reperformance No.
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'No: violations or deviations were identified.
6.
Preoperational Te'st' Result's Verification
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The inspecto'r verified that the following preoperational t'est results were documented, reviewed and approved by the licensee in accordance
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with the. requirements.of Regulatory Guide:1.68, the TPM,'the FSAR, the SER, and the QA Program and found them satisfactory.
TP 1N32-A001, " Turbine Control EHC," Revision 0 TP 1N64-A001, "Off gas Charcoal Vault Refrigeration," Revision 0 TP 2M42-A001, " Turbine Power Complex Ventilation," Revision 0 TP ~1C51C-P001, " Recirculation Flow Bias Subsystem," Revision 0 TP.1C34-P001, "Feedwater~ Level Control," Revision 1 zTP 1F13-P001, " Vessel Servicing Equipment," Revision 0
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TP 1G60-A001, '! Miscellaneous Sump System," Revision 0 TP 1R43-P001, " Division 1 Standby Diesel Generator," Revision 1
- TP 1R25-P001, "120V AC'1E Instrument and Miscellaneous Distribution Panels," Revision 0 TP 1E22-P002, "High Pressure Core Spray Diesel Generator," Revision 1 TP 1R43-P002, " Division 2-Standby Diesel Generator," Revision 1
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No violations or deviations were identified.
7.
Preoperational Test Results Review The inspector reviewed the results of the following tests against the FSAR, the SER, Regulatory Guide 1.68, the QA Manual, and the Test Program Manual, and determined that test changes and test exceptions were processed in accordance with administrative controls, test deficiencies were identified, processed, and corrected as required, results were evaluated and met the acceptance criteria, and the results were reviewed and approved as required.
TP 1E15-P001, " Containment Spray System," Revision 0
TP 1M15-P001, " Annulus Exhaust Gas Treatment System,"
Revision 2 TP 1M56-P001, " Hydrogen Igniter System," Revision 0
TP OM25/26-P001, " Control Room HVAC and Emergency
Recirculation System," Revision 3 TP OM40-P001, " Fuel Handling Building Ventilation System,"
Revision 1
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TP 1C41A-P001, " Standby Liquid Control System," Revision 0
No violations or deviations were identified.
8.
Preoperational Test Program Implementation a.
The inspector randomly selected three approved test procedures and verified that the review and approval were in accordance with administrative procedures.
Per the requirements of TPI-27,
" Release for Test:
Preoperational and Acceptance Tests," testing is to be conducted to the system's as-built configuration at the time of the test.
A listing of drawings depicting the as-built configuration covered by the test is developed and included in the Release for Test (RFT) package.
The inspector reviewed the RFT packages for two test procedures and verified that applicable drawings had been listed.
In addition, verifications in the RFT packages had been completed ensuring that the test procedure had been written to the latest revision of design documentation listed in the test procedure reference section and that test changes and exceptions had been submitted to test to the as-built configuration.
Prior to the release for test, Nuclear Test Section (NTS) as-built.
drawings are submitted to the Systems Engineering Response Team (SERT).
Any missing drawings are placed on the Master Deficiency List (MDL) and evaluated for impact on testing.
The inspector reviewed documentation which verified that NTS as-built drawings had been submitted to SERT for these same test procedures.
b.
Per the requirements of TPI-27, the Software Pretest Checklist is to be included in the RFT package with verifications that completed design changes have been incorporated into the test,
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incomplete design changes-have been placed on'the MDL and reviewed for impact on testing,'and pending' design changes have been reviewed with'the Lead Test Engineer.
The inspector reviewed two RFT packaaes and verified that these verifications had been completed.
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The.,;ector also verified by direct questioning of a System Test Engineer and I&C Supervisor that they appeared to be familiar with
' administrative controls covering the conduct of corrective and r
preventative maintenance during preoperational testing.
No violations or deviations were identified.
9.-
Startup Test Procedure Review
'The inspector reviewed the following approved test procedures against the FSAR, the SER, Regulatory Guide 1.68, QA Manual, appropriate licensee administrative procedures, applicable Regulatory Guides and ANSI Standards
.and docketed correspondence.and found them satisfactory except as noted below:
a.
STI-821-026, " Safety Relief Valves," Revision 0 b.
STI-B21-027, " Turbine Trip and Generator Load Rejection," Revision 0 c.
STI-C61-028, " Shutdown From Outside the Control Room," Revision 0 d.
STI-R43-031, " Loss of Turbine Generator and Offsite Power,"
Revision 0 e.
STI-J11-003, " Fuel Loading," Revision 0 During the review and resulting discussions the licensee indicated the following' changes would be made to the procedure:
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Regulatory Guide 1.68, Appendix C, Section 2.b(3) indicates that the procedure should ensure " proper seating and orientation of fuel and components. A visual check of each assembly in.each core position should be specified." The procedure verifies this per Section 8.2, " Verification of Core Loading," which is performed following loading of all!the fuel assemblies.
In order to ensure that the intent of the regulatory guide is met, the licensee has agreed that either this procedure, or a corresponding fuel handling instruction used in conjunction with this procedure will be re' vised to include observations to be made while in the process of loading fuel that ensure correct orientation of assemblies.
Regulatory Guide 1.68, Appendix C, Section 2.c(1) indicates
that the procedure -hould contain criteria for stopping fuel loading including, among other circumstances, an inoperable source-range detector.
Although the procedure may imply
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7this re_quirement for an inoperable source-range detector,
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- itDis not explicitly stated as tit is for the other_ criteria.
.-In. order to provide. clarification,.the licensee has: agreed
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0" Ito explicitlyistate =in the procedure the criteria involving
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inoperable? source-range; detectors in regards to suspending.
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-core alterations.
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Per the note following step 6.2.7 of the procedure,
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... technical sp'ecifications which are required to be
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verified within.24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less prior to beginning core'-
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i alternations are listed separately in.Section 6.3, Initial
' Conditions for. Fuel Loading." However,:Section 6.3'does~
not include surveillance requirements of Technicalc Specification Section 4.9.1.2, that the reactor mode"
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' switch refuel interlocks shall be. demonstrated operable
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by a channel functional test within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to core-alterations..This requirement would have been included
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anyway by the completion of step 6.2.7 which prescribes verification that all applicable technical specification surveillances:are complete and current and.all equipment required by technical specifications for: operational condition 5.is operable per-PAP-1114,z " Operational-
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. Condition Change Checklist." - The operational' condition change checklist for preoperational to operational-
' condition.5 includes the subject surveillance. The licensee-has,.however, agreed to also include'this-surveillance requirement in Section 6.3 of the test procedure in order to provide procedure consistency.
This is to remain an open item until the procedure is revised to incorporate these indicated changes (440/85063-02(DRS)).
- In addition, the following approved test procedures are
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(currently under review and will be completed in a
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subsequent inspection.
STI-J11-021, " Core Power Mode Response,"
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Revision 0 STI-C51-006, "SRM Performance and Control Rod
. Sequence,'? Revision 0
.STI-C11-005, " Control Rod Drive System,"
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Revision 0 STI-J11-004, " Full Core Shutdown Margin,"
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Revision 0
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STI-C51-011, "LPRM Calibration," Revision 0
STI-C51-012, "APRM Calibration," Revision 0
STI-B21-025A, "MSIV Function Test,"' Revision 0
.STI-C91-018,." Core Power Distribution," Revision 0 e
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No violations or deviations were identified; however, a portion of the area requires further review and is considered an open item.
10.
Unresolved Items Unresolved items are matters about which information is required in order to ascertain whether they are acceptable items, violations, or deviations.
The unresolved item disclosed during the inspection is discussed in Paragraph 4.b.
11.
Open Items Open items are matters which have been discussed with the licensee which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both.
The open item disclosed during the inspection is discussed in Paragraph 9.e.
12.
Exit Interview The inspector met with licensee a:presentatives denoted in Paragraph 1 on October 18, 1985. The inspector summarized the scope and findings of the inspection and discussed the likely content of this inspection report.
The licensee did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature.
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