IR 05000443/1985023

Insp Rept 50-443/85-23 on 850805-08.No Violation Noted.Major Areas Inspected:Preoperational Test Witnessing,Qa Interface W/Preoperational Testing & Independent Calculations

ML20135G439
Person / Time
Site:	Seabrook
Issue date:	09/11/1985
From:	Briggs L, Eselgroth P, Marilyn Evans, Oliveira W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20135G437	List: IR 05000443/1985023 ML20135G436
References
50-443-85-23, NUDOCS 8509190091
Download: ML20135G439 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-23 Docket N License N CPPR-135 Category B Licensee: Public Service Co. of New Hampshire 1000 Elm Street Manchester, New Hampshire 03105 Facility Name: Seabrook Station, Unit 1 Inspection At: Seabrook, New Hampshire Inspection Conducted: August 5-8, 1985 Inspectors: vhJf C. Briggs, LFad Reactor Engineer

_f/t 8 date

]6 M. Eva frwo RyactorEngineer 0 blW da e '

i 1 e c or Engineer da Approved by:

P. Eselgroih', Chief _, Test Programs 9////6 date Section,MB, DRS Inspection Sumtriry: Inspection on August 5-8, 1985_(Report No. 50-443/85-23)

Areas Inspected: Routine, unannounced inspection by three region-based inspec-tors (82 hours9.490741e-4 days <br />0.0228 hours <br />1.35582e-4 weeks <br />3.1201e-5 months <br />)ofpreoperationaltestwitnessing,preoperationalandaccep-tance test results evaluation review, preoperational test program implementa-tion, QA interface with preoperational testing, independent calculations and facility tour Results: No violations were identifie PDR ADOCK 05%l3

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DETAILS 1.0 Persons Contacted ,

J. Azzopardi, Quality Assurance (QA) Engineer (NHY)

S. Baldacci, QA Engineer (YAEC)

"S. Barraciough, QA Engineer (YAEC)

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• R. Guillette, Assistant Construction QA Manager (NHY)

L. Jacobson, Calibration Facility Superviser (NHY)

• G. Kann, Phase 2-6 Te.t Group Manager (NHY)

G. Kingston, Station Staff Compliance Manager (NHY)

D. Lambert, Field Quality Control (QC) Manager (NHY)

J. Marchi, Startup QC Manager (NHY)

• G. Mcdonald, Construction QA Manager (NHY)

• Middleton, QA Staff Engineer (NHY)

• D Perkins, QA Engineer (NHY)

J. Peterson, QA Engineer (YAEC)

• W. Sanchez, Engineer, Licensing (NHY)

J. Singleton, Assistant QA Manager (NHY)

• J. Tefft, Startup and Test Department Special Assistant (NHY)

W. Temple, Startup and Test D2partment QA Supervisor (NHY)

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M. Toole, System Test Engineer (Reactor Protection System)

T. Waechter, Startup Test Engineer (Safety Injection System)

Other NRC Personnel Present I

i *R. Barkley, Reactor Engineer i *A. Cerne, Senior Resident Inspector i

i * Denotes those present at August 8, 1985 exit meeting,

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! 2.0 Preoperational Test Witnessing

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During the entrance meeting on August 5, 1985 the licensee informed the inspector that no preoperational tests of safety related systems were scheduled to be conducted during the week. However, the acceptance test

of the 125 VDC Non-Vital Distribution System, 1-AT-66, was in progress.

In preparation for test witnessing the inspector reviewed the latest

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revision of the acceptance tes .1 Scope j Testing was witnessed by the inspector for the observation of over-all crew performance as stated in Paragraph 2.1 of Inspection Re-port 50-443/85-16.

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I 2.2 Discussion

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On August 7, the inspector observed a portion of the performance of Paragraph 6.3.10, monitoring of battery terminal voltage and individ-ual cell voltages with the Alber Electronic Control Unit / Data Logger. The inspector verified that testing was being conducted in a controlled manner and met the attributes stated in Paragraph 2.1

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abov .3 Findings No unacceptable conditions were observe > 3.0 Preoperational and Acceptance Test Results Evaluation Review l 3.1 Scope

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j The completed test procedures listed below were reviewed during this inspection to verify that adequate testing had been conducted to sa-i tisfy regulatory guidance, licensee commitments and FSAR require-

] ments and to verify that uniform criteria are being applied for evaluation of completed test results in order to assure technical and administrative adequac The inspector reviewed the test results and verified the licensee's evaluation of test results by review of test changes, test excep-tions, test deficiencies, "As-Run" copy of test procedure, accep-l tance criteria, performance verification, recording conduct of test, l QC inspection records, restoration of system to normal after test, l independent verification of critical steps or parameters, identifi-

, cation of personnel conducting and evaluating test data, and veri-fication that the test results have been approve PT-8, ECCS Performance Test, Revision 1, Results Approved July 31, 1985;

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1-PT-12.1, Containment Spray System Operational Test,

] Revision 2, Results Approved July 31, 1985;

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1-PT-18, Nuclear Instrumentation System, Revision 0, Results

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Approved July 31, 1985;

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1-AT-3.1, Condensate System, Revision 1, Results Approved July 31,1985; and

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1-AT-37, Feedwater Pump Lube Oil System, Revision 1, Results Approved July 31, 1985.

I The inspectors also conducted a preliminary review of 1-PT-19.1, i Reactor Protection System, which was completed August 4, 1985 and i

has not yet been reviewed and approved by the license _ - - _ _ - - _ _ _ _ _ _ _ _ - _ _ - - - _ _ _ _ _ _ _ _

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3.2 Findings No discrepancies or violations were identified during the above review; however, there were several test exceptions that require licensee corrective action. These test exceptions were assigned to the incomplete items list (IIL) by the licensee for tracking purposes (normal method at this facility). Once transferred to the IIL the test exception is closed by the licensee with corrective

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action implemented via the II The following IIL numbers correspond to incomplete test exceptions and collectively constitute unresolved Item 443/85-23-0 Procedure N Short Title IIL N ,

-- 1-PT-8 ECCS Performance SI-0459, 51-0458, and RH-0400

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-- 1-PT-1 Nuclear Instrumentation NI-0093, NI-0094 and NI-0092

-- 1-PT-1 Containment Spray CBS-0595 and CBS-0594

-- 1-AT- Condensate CAS-0192 4.0 Preoperational Test Program

, 4.1 Test Organization 4.1.1 Scope This portion of the inspection was to assure through review of activities and documents and interviews with personnel that:

' Key test personnel understand their responsibilities as well as the lines of authority in the test organ-ization.

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' There is a method and responsibility for selecting and training of test personne . There are organizational interfaces for other organ-izations in the test progra .1.2 Discussion

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The Startup Test Department (STO) was established as a temporary on-site organization to provide a smooth and orderly transition from construction to operation, and the concomitant transfer of authority from Construction to the Station Staff,

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The STD is responsible for (1) the overall scheduling, admin-istration and technical direction of the initial test program;

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(2) coordination of turnover systems and equipment at completion-of construction; (3) development of initial test procedures; (4)

performance of initial test procedures; and (5) coordination of

! turnover of systems and equipment to the Station Staf l I The responsibilities of kay personnel as well as the lines of ,

i authority are adequately discussed in Appendix A of the Pre- '

s operational Test Program Description in the Preoperational Test

! Program Manual. The selection, training and qualifications of test personnel are adequately described in Test Program Instruc- '

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tion (TPI)-81, Qualification and Certification of Test Person-i nel. The organizational interfaces are also described in the l l Preoperational Test Program Manual and other organizational

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manuals such as the Seabrook Station Quality Assurance (QA)

Manual, j There was no phase 2 preoperational testing in progress. The j inspector therefore walked through the QA surveillance effort j for Preoperational Test (PT) 19.1 Revision 0, Reactor Protec-

', tion System (Instrument and Control (I&C)). The review is j further discussed in paragraph 5.0.

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. The status of the Suspense Listing for August-1, 1985 was reviewed with the STD Technical Support Supervisor. This list '

is prepared and submitted by the QA Surveillance Group to management. The list contains Surveillance Reports (SRs), Def-

iciency Notices (DNs) and Audit Findings, that are outstanding ,

i open items. STD has provided replies to QASR findings, some of  :

which include requests for extension of time to close out the l item The inspector (s) observed the following activities:

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(1) Preparation for stroking the thermal barrier isolation i

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MOVs in accordance with General Test Mechanical GTM-0 (2) Hydrostatic Integrity Test (IT) of the Feed water ASME and

! ANSI B31.1 (non ASME) pipin The procedure used for the i test was Pullman Higgins (P-H) test procedure FW-IT-05.

The test was conducted by STD under the direction of P-H "

i Test Director. The test was witnessed by QA personnel and

. Authorized Nuclear Inspectors (ANI). The STD systems en-gineer inspected the ANSI B31.1 piping during the hydro-static test.

a l (3) Screen Wash System Filter SCW 185A and 185B flange

! ' connections being retorqued.

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(4) Acceptance Test No. 1-AT-66, Revision 0, 125 VDC Non-Vital Distribution System Test. Battery Service Test (para-graph 6.3) was in progress when the inspectors arrived. A Station Staff Engineer was also observing the test. The test proceeded in accordance with 1-AT-66. The measuring and test equipment (M&TE) used for the test were cali-brated and the test personnel were knowledgeable in the use, limitation and care of the M&TE. (see paragraph 4.3.2).

(5) Repair to a limit switch to a Service Water MDV performed to Work Request (WR) 1264 in the presence of the STD elec-

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trical system engineer and the QC inspector. The system engineer decided that part of the repair was not necessary and was preparing an exception repor .1.3 Findings No unacceptable conditions were observe .2 Design Changes and Modifications 4.2.1 Scope Three design change packages were selected to determine com-pliance with procedures and that the cognizant engineers (STD)

were aware of the change. The inspector also observed tempo-rary strainers installed and the installation of permanent spectacle flanges to replace the temporary blank flange .2.2 Discussion Design Changes and the subsequent Engineering Change Authoriza-tion (ECAs) are generated primarily when the component, equip-ment or system would not function as designed or in response to a licensing issue. The procedure for a Design Change Notice (DCN) and the subsequent engineering change authorization (ECA)

initiated by STD is as follows:

(1) A Request for Information (RFI) is issued by STD to United Engineers and Constructors Inc. (UE&C) for their review and approva (2) Upon approval a Design Change Notice (DCN) is developed by UE&C and submitted to Yankee Atomic Electric Company (YAEC).

(3) YAEC has a Change Control Team (CCT) consisting of Engineer-ing, Construction, and STD who review the DC _

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(4) An ECA will be processed in accordance with UE&C Administra-tive Procedure (AP)-15, Revision 22, Project Design Changes and ECA (5) The ECA is issued as a working document for implementing the design chang '

Three recent DCN/ECAs, 19/107086A, 19/107708A, and 19/107952A were selected. These were developed in accordance with AP-10, Revision 0, DCN and Budget and Expense Revision, and AP-1 The affect of these ECAs on STD test procedures was being reviewed. The inspector reviewed ECA 19/803755A for which the systems engineer had determined that a supplement rather than a change or revision to the test procedure was necessar The means used by the sys ems engineer for tracking the DCN/ECAs are the Incomplete Item List (IIL) and the new Change Document Tracking System (CDT). The systems engineer must research the DCN/ECAs and determine what STD documentation is or will be affected by the DCN/ECA The CDT is expected to assist the systems engineer make that determinaticn more quickl .2.3 Findings No unscceptable conditions were observe .3 Measurement and Test Equipment (M&TE)

4.3.1 Scope The inspector selected four M&TE that were being used for a test, reviewed the applicable calibration records and verified that the administrative controls have been implemente .3.2 Discussion STD test personnel used M&TE for Acceptance Test 1-AT-6 The STD test personnel were knowledgeable of the procedures and requirements for:

(1) selecting and requesting the proper M&TE for the tes (2) completing the usage log upon receipt of the M&TE from the storeroo (3) noting and recording the calibration due dat (4) knowing the limitations of the M&TE used for the tests.

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8 (5) care of the M&T (6) returning the M&TE to the storeroom and reporting any problems regarding the M&T The M&TEs selected were: FLS-534, Temperature Probe; FLS-774, Hydrometer; FLS-784, Battery Capacity Test System; and FLS-968, Volt Ohm Meter. The calibration records located in the Cali-bration Facility were current and complete. The calibration facility personnel were knowledgeable of the requirements of administrative procedure MA 2.3. In the case of FLS 534, the probe recalibration results were unsatisfactory and STD was notified. STO reviewed the usage log and the data taken. The probe was repaired, calibrated satisfactorily and issued for use to the storeroo .3.3 Findings No unacceptable conditions were observe .4 Training 4.4.1 Scope Ten STO test personnel were interviewed and the training records of two STD qualified test directors were reviewe .4.2 Discussion The interviews were tailored to the activity being performed by the test personnel whether the training for the activity was received at Seabrook or elsewhere. All the test personnel ac-knowledged that the training received at Seabrook was job related, adequate, timely, well presented and administratively controlle The records of the two STD qualified test directors were com-plete, current and training including QA/QC indoctrination was in compliance with TPI-81, RG 1.58 (ANSI N45.2.6 - 1978) and ANSI 3.1-197 .4.3 Findings No unacceptable conditions were observe .0 QA/QC Interface with the Preoperational Test Program 5.1 Program and Implementation Review Construction QA is responsible for providing the required quality

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assurance support for any STD or construction activities associated with post-Conditional Acceptance Turnover (CAT) systems, structures, or components. This will be accomplished in accordance with the Seabrook Station Quality Assurance Manua Two sections in Construction QA (CQA) primarily involved in the STD effort are:

(1) The Project QA Surveillance Startup, and (2) The Project Startup Q QA surveillance of a preoperational test (PT) was demonstrated in the walk through of PT 19.1, Reactor Protection System (I&C). The QA engineer (QAE) in accordance with TPI-64 receives an advance copy of the TP. Using the master checklist in TPI-64 as a guide, the QAE " red stamps" action paragraphs and steps for QA verificatio i

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The QAE also sends a memorandum to STD listing the action paragraphs or steps requiring QA verification. The red stamp is signed whether the action or step is witnessed or not. The QA verification is a check for compliance with the FSAR requirements and not a technical review. Other QA surveillances are performed in accordance with the Field QA Group Manual and Procedure. Deficiencies that are not corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are noted on Surveillance Reports (SRs).

Five SRs were reviewed and found complete with an applicable check-list. The SRs are submitted to STD and processed through a Joint Test Group in accordance with TPI-65. A Deviation Notice (DN) is prepared with a request for corrective action (CA) within five working days for more severe or trend type deficiencies. Outstanding open SRs and DNs are reported on the Suspense list for STD immediate actio Startup QC provided coverage for the repair of the Service Water MOV limit switch. The QC inspector discussed and concurred with the exception to the repair procedure taken by the STD system enginee The actions leading to the exception and the data recorded were in accordance with TPI-6 Three QA Surveillance Startup and two Startup QC personnel were in-terviewed to assess the adequacy of training. The interviews were tailored to the activity being performed by the personnel. The training was job related, adequate, timely, and administratively controlled. The qualification and training records of the three QA

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Surveillance Startup personnel were complete, currert, and in accord-ance with the Seabrook Station QA Manual. Six 1985 QA audits of STD were reviewed. These audits were scheduled, prepared, conducted, reported, issued and followed up in accordance with Seabrook Station QA Manua The corrective actions were timely and responsive to the

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identified concerns. The audits were in-depth and conducted against 10 CFR 50.55e. Outstanding open audit findings are listed in the Suspense List for STD's immediate actio .2 Findings No unacceptable conditions were observed. The Field QA Manual and Procedure document however, did not address the requirement to notify the QA Surveillance Startup Group of phase 2 (System Acceptance /

Preoperational Tests) and phase 3 testing (Integrated System Pre-operational Tests). A memorandum from the QA Surveillance Startup Group Supervisor to the STD Manager requested that the group be notified of phase 2 and 3 testin .0 Independent Calculations The inspector performed independent pump head and net positive suction head (NPSH) calculations during the results evaluation review discussed in paragraph Findings No unacceptable conditions were note .0 Plant Tours The inspector made several tours of various areas of the facility to ob-serve work in progress, housekeeping, cleanliness controls, status of construction and preoperational testing activitie Findings No unacceptable conditions were note .0 Unresolved Item Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, an item of noncompliance or a deviation. The unresolved item identified during this inspection is discussed in Paragraph 3.2 of this repor .0 Exit Interview A management meeting was held at the conclusion of the inspection on August 8, 1985, to discuss the inspection scope, findings and observa-tions as detailed in this report (see Paragraph 1 for attendees). No written information was piovided to the licensee at any time during this inspection. The licensee indicated that no proprietary information was contained in the scope of this inspection.