ML20031G036

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IE Insp Rept 50-245/81-13 on 810810-14.Noncompliance Noted: Failure to Provide Acceptance Criteria & Detailed Instructions,Follow Written Procedures & Review & Document Test Results Properly
ML20031G036
Person / Time
Site: Millstone Dominion icon.png
Issue date: 09/25/1981
From: Caphton D, Chung J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20031G028 List:
References
50-245-81-13, NUDOCS 8110200680
Download: ML20031G036 (15)


See also: IR 05000245/1981013

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U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

Region I

Report No.

50-245/81-13

Docket No.

50-245

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License No.

DPR-21

Priority

-

Category

C

Licensee:

Northeast Nuclear Energy Company

P.O. Box 270

Hartford, Connecticut 06101

Facility Name:

Millstone Nuclear Power Station Unit 1

Inspection at:

Waterford, Connecticut

Inspection con etcd: August 10-14, 1981

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Inspectors:

m /O R

c.1 /

in W. Chung

date signed

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date signed

date signed

Approved by: MMNM4+<- A

9 -M S/

,

D. L. Caphton, Chief, Test Program

date signed

Section, Engineering Inspection Branch

Inspection Summary:

Inspection on August 10-14,1981 (Report No. 50-245/81-13)

Areas Inspected: Routine, unannounced inspection of cycle 8 post refueling startup

testing, which includes pre-critical scram times and hydro tests; shutdown margin

and critical rod configuration; and power escalation tests.

The inspection involved 31 inspector-hours on site by one region-based inspector.

Resul ts:

One item of noncompliance:

Failure to provide acceptance critoria and

detailed instructions; to follow written procedures; and to review and document

test results properly - section 4).

Region I Form 12

(Rev. April 77)

0110200600 811001

PDR ADOCK 05000245

O

PDR

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_ DETAILS

1.

Persons Contacted

Principal Licensee Employees

    • R. Herbert, Unit 1 Superintendent
  • E. J. Lindsay, Reactor Engineer
  • E. J. Mroczka, Station Superintendent
  • R. J. Palmier, Engineering Supervisor

F. W. Teeple, Unit 1, I&C Supervisor

  • K. B. Thomas, Senior Engineer

J. Stetz, Unit 1, Operations Assistant

USNRC

  • D.

R. Lipinski, Resident Inspector

The inspector also interviewed other licensee employees during the inspec-

tion, including Reactor Operators, performance and administrative personnel.

    • Licensee representative at the Exit Interview

-* denotes those present at the Exit Interview

2.

Cycle 8 Startup Testing - Precritical Test

a.

The inspector reviewed functional and calibration tests'and results to

verify the following:

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Procedures were provided with detailed instructions;

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Technical content of procedures was sufficient to result in

satisfactory component calibration and test;

--

Instruments and calibration equipment used were traceable to the

National Bureau of Standards;

--

Acceptance and operability criteria were observed in compliance

with Technical Specifications.

)

b.

The following tests were reviewed:

(1) Control Rod Drive; Scram Insertion Time

Scram insertion time had been measured on April 19, 1981 for 5%,

20%, 50%, and 90% insertions from fully withdrawn positions.The

test procedure employed was SP 1051, Control Rod Scram Time Test,

Revision 3, November 12, 1979. The inspector verified that the

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average scram insertion times were all within the limits specified

in Technical Specification 3.3.C except control rod drive 22-51.

Control rode drive 22-51 did not meet the 7.0 second insertion

limit for 90% insertion as required by Technical Specification 3.3.C.3.

The failed drive 22-51 was retested on April 20, 1981, again

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exceeding 7.0 second insertion specification. This drive was

subsequently replaced and the scram insertion times were

successfully demonstrated on June 27, 1981.

The documents reviewed include:

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Scram insertion time tests performed April 19, 1981 for

all control rods; April 20, 1981 and June 17, 1981 for

control. rod 22-51.

--

Job Order No. 181-202, 22-51 Drive Replacement, May 4, 1981.

Findings

Procedure SP 1051 requires that scram insertion times be recorded on

RE Form 1051-3 and the average values of 145 rod insertion times be com-

pared with the acceptance limits.

Test records for April 19, 1981' showed

that the average values were not recorded-in the RE 1051-3 data sheet.

Technical Specification 3.3.C.3 specifies that the maximum scram

insertion time for 90% insertion of any operable control rod be less

that 7.0 seconds. The scram time tests performed April 19,

1981 at 145 MWe identified that the 90% insertion time for the

control rod 22-51 was 7.46 seconds, exceeding the required 7.0

seconds. However, neither subsequent action per Technical

Specifications nor any corrective actions such as a maintenance

request / replacement job order were specified in the test'

package.

Instead, the failed rod was retested the following

day, April 20. 1981 at 80 MWe; again failing the 7.0 second

Technical Specification. Again, no subsequent actions were

documented in the test record. However, it was determined

that corrective action was taken May 4, 1981.

During this inspection it took more than a day for a cognizant licensee

engineer to identify the Job Order Number from the separate file based

on his personal memory. These failures to follow written procedure

and to document the test results properly, constitute an example of

noncompliance as summarized in Sec. tion 4.

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(2) Hydrostatic Pressure Test

The inspector verified by review of test procedures, changes, and

test data that the pressure tests of the Reactor Vessel and

Class I piping system and components had been completed in

accordance with procedures, in that:

--

The hydro test was performed April 8-9, 1981 using procedures

SP o0-1-25, Hydrostatic Pressure Test of the Reactor Vessel

and Class I Piping System and Components, Revision 1,

June 18, 1980 and Operations Form 80-1-25-1, RPV Hydrostatic

Test Inspection Checklist, Revision 1, March 14,1981;

--

The pressure test of Standby Liquid Control System was

performed March 17, 1981 using a special test procedure,

SP 80-1-38, Hydrostatic Pressure Test of the Standby Liquid

Control System Valves 1-SL-9 and 1-SL-7, Revision 0, June 18,

1980;

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A portion of piping penetrations for,the Reactor Core Spray

System was replaced with new material per Plant Design

Change Request (PDCR) No. 1-58-76 and PDCR Design Review and

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Safety Evaluation dated October 12, 1980.

The separate

hydrostatic test for the new core spray penetrations was

performed March 9, 1981 in accordance with the procedure SP

80-1-16, Hydrostatic Test of Reactor Core Spray Loops A and

B, Revision 0, June 18, 1980.

No unacceptable conditions were identified.

(3) Reactor Core Verification

The inspector determined that the core verification test was

performed April 1,1981 using procedure RE 1077, Reactor Core

Verification, Revision 3, March 20,1981, in which the following

were identified:

--

Fuel assembly serial numbers were in accordance with the

core maps;

Fuel assemblies were properly oriented and seated;

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Channel fasteners were intact;

No foreign matter was found on fuel assemblies.

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The inspector had no further questions.

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3.

Cycle 8 Startup Testing - Post-critical Tests

a.

The inspector reviewed selected test programs to verify the follow-

ing:

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The test programs were implemented in accordance with Cycle 8

Refueling Sequencing Procedures;

Step-wise instructions for test procedures were adequately

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provided, including Precautions, Limitations and Acceptance

Criteria, in conformance with the requirements of the Technical

Specifications;.

Provisions to recover from anomalous conditions were provided;

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Methods and calculations were clearly specified and the tests

were performed accordingly;

Review, Approval, and Documentation of the results were in

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accordance witn the requirements of the Technical Specifi-

cations and the licensee's administrative controls.

b.

The following programs were reviewed:

(1) Shutdown Margin Demonstration

The inspector verified by an independent calculation and

review of the Shutdown Margin (SDM) procedure and test data per-

formed April 17, 1981, that the SDM with the strongest control

rod fully withdrawn was 2.13%Ak/k. Technical Specification 4.3.A.~1 requires SDM value greater than 0.33%Ak/k.

The SDM was determined by the "in-sequence" method in the

Xenon-free state and with tae moderator temperature of 172'F.

The reactor achieved criticality at 2147 hours0.0248 days <br />0.596 hours <br />0.00355 weeks <br />8.169335e-4 months <br />, April 17,

1981. The critical rod configuration was attained with

the rod 22-15 in group 2 at 16 notch position > " with the

reactor period of 290 seconds.

The test results were:

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Reactivity Contribution

Reactivity, %Ak/k

Control Rod Worth Less

(Strongest Rod: 30-23)

- 2.86

Rod Worth at Criticality

+ 5.10

Temperature Coefficient Correction

- 0.08881

Period Correction

- 0.023

Maximum decrease from BOC(R)

G0

Shutdown Margin

2.13

Technical Specification 3.3.A.1

0.33

The documents reviewed were:

SP 690B, Reactivity Margin - Core Lo'ading Shutdown Margin

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Test, Revision 4, October 31, 1979.

Operations Form 690B-1, Data Sheet, Revision 3, November 14,

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.1979. Test performed April 17, 1981.

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Cycle 8, Millstone Unit 1 Cycle Management Report, Revision 0,

GE Document No. 22A6889, November 14, 1980.

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Findings

Operations Form 6908-1 requires extensive utilization of the

figures and tables in the cycle management report in order to

calculate the various reactivity contributions to the SDM. The

inspector identified the following inadequacy and incorrect

instruction in the Operations Form 6908-1:

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The formula in step 7.4.5 of the Operations Form 6908-1

specified that the item (4) be subtracted from 1.000 for

the SDMK

calculation.

A correct sign should be "+"

eff

rather than " ".

Consequently, the shutdown margin obtained

was incorrect;

Item (1) in step 7.4.1 requires data from Table 5, Section 7

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of the cycle management report. This was not specified in

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the procedure;

Step 7.4.1, item (2), and step 7.4.3 require information

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from figure 10,_B-sequence, and figure 11, respectively,

in the management report. -The procedure did not specify

the references nor were the figures attached;

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Table 5, Section 7 of the cycle management report is required

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to calculate the quantities identified in the procedural

steps 7.4.2 and 7.4.4.

The procedure did not provide the

above information.

The above failures constitute an example of noncompliance summarized

in section 4.

(2) Critical Rod Configuration and Reactivity Anomaly

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The inspector reviewed procedure SP 1050, Critical Rod Configuration

Comparison, Revision 1, July 26,1978 and test data of SP Form

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1050-1 performed June 29, 1981, and verified that the actual control

rod configuration was within 1%Ak/k of the predicted value as

specified in Technical Specification 3.3.E.

The table below

summarizes the reactivity anomaly test results. The inspector.

calculated the results iadependently from the data sheet 1050-1

and figures in the GE Cycle Management Report:

Steady State

Critical

(157.43 MWD /ST Burnup)

Notches Withdrawn

Actual

1204

6390

Predicted

1008

6344

Reactivity, %Ak/k

Actual

5.35

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Predicted

4.45

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Difference

0.90

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Acceptance *

<l.00

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Notches Inserted

Actual

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570

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Predicted

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616

Acceptance **

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( <l .0%Ak/k)

  • figure 10, cycle 8, GE Cycle Management Report
    • figure 6, Cycle 8, GE Cycle Management Report

Findings

The procedure SP 1050 requires recording of a reactor period

in seconds on the SP Form 1050-1. The test data for June 29,

1981, did not have the period recorded.

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Furthermore, neither procedure SP 1050 nor SP Form 1050-1

specified acceptance criteria or re ferences to determine the

acceptability of the test data. The inspector further determined

that the control rod notches withdrawn as specified in the data

form were not directly comparable with the figures in the cycle

management report to determine the test acceptability. The summary

presented in the previous table was constructed by the inspector,

employing the following calculational steps:

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The actual and predicted notches withdrawn at the

critical state were 1204 and 1008 notches, respectively,

on the data sheet SP Form 1050-1. These notches had to

be converted into the numbers of rods withdrawn by

dividing by 48. Entering these numbers (25.1 and 21

rods each) into the abscissa of the figure 10, cycle

management report, the ordinate readings would give the

reactivity worths for the predicted and the actual

configurations. The difference of the two would be

compared with Technical Specification limit. None of

the above steps and reference figures were specified in the

procedure.

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During the steady state operation with a significant

number of rods withdrawn, the upper and the lower curves-

in figure 6 of the report would provide the upper

and the lower bounds of the Technical Specification limits

in terms of the number of rods inserted, and the middle

curve would be the predicted number of rods inserted. The

number of notches withdrawn on SP Form Form 1050-1 had to

be converted into the notches inserted by subtracting the

withdrawn notches from 145x48 = 6960, and then by dividing

the notches inserted by 48.

None of the above steps and reference figures were either

identified or attached in t's procedures.

The above findings constitute an example of noncompliance as

suinmarized in section 4.

(3) Traversing Incore Probes (TIP) - Asymmetry Check

The inspector reviewed the TIP traces and test conducted on

July 28, 1981 to ascertain plant TIP uncertainty. The inspector

determined that the test was performed in accordance with the

procedure RE 1058, TIP uncertainty, Revision 0, June 29, 1980 and

the TIP uncertainty of 5.699% was within the acceptable deviation

of 7% recommended by the General Electric Special Procedure

78-1-37, Revision 0, March 19, 1978.

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The Standard Deviations for the TIP noise and the location

uncertainty were 1.806% and 5.978% respectively.

The TIP

uncertainty due to the location and the noise perturbations was

obtained by taking a geometric average of the two separate

contributions.

The inspector had no further questions.

(4) TIP - Hot Alignment

The inspector reviewed procedure IC-405L. Axial Alignment of

Traversing Incore Probes, Revision 2, June 18, 1980 and I&C

Form 405L data sheet performed July 28, 1981. The inspector

verified that Turn-Around-Margin of all four TIP's were

greater than 2 inches. This satisfied the requirements.

The inspector had no further questions.

(5) Jet Pump Baseline Data Collection

The inspector verified that the baseline data, which included

recirculation flow, motor generator set speed, and scoop tube

position, were obtained in accordance with Procedurc SP 1052,

Revision 2, July 10,1980.

The jet pump baseline data reviewed were:

Power, %

Test Date

62.00

7-3-81

68.89

7-3-81

79.50

7-3-81

90.20

.7-4-81

99.20

7-8-81

The inspector had no further questions.

(6) Fuel Parameter Verification

The inspector reviewed procedure RE 1057, Process Computer

Fuel Parameter Input Verification, Revision 0, March 28, 1981,

and determined that the process computer inputs of April 16, 1981,

for Maximum Planar Linear Heat Generation Rate (MPLHGR) and

Minimum Critical Power Ratio (MCPR) were in accordance with

Technical Specification 3.11.1, figures a, b, c, d, e, f, and g.

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Findings

The objective of this test was to verify the process computer

inputs against MAPLHGR and MCPR limits specified in Technical Specifications 3.11.1 figures for seven different fuel types.

The test data packages did not specify the acceptance criteria

or references, nor was there any objective evidence that the

process computer input for April 16, 1981 was verified against

the figures in Technical Specifications.

These findings are an example of noncompliance summarized in

section 4.

(7) Exposure Surveillance

The inspector reviewed procedure SP 1041, Planar Average Exposure

Surveillance, Revision 2. September 10, 1980, and tests

conducted on June 26 and July 31, 1981, including the "on-demand"

computer printouts.

The inspector verified by an independent

review of the test results that both results were within the

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- requirements specified in Technical Specifications.

The two test results were:

6/26/81

7/31/81

Fuel Assembly XX-ZZ

with >23,5000 MWD /T

03-16

03-16

Maximum Nodal Exposure

ZZ

08

08

Exposure, MWD /T

29,438

29,809

'

Acceptance, MWD /T

30,000

30,00'

MAPLHGR, KW/ft

3.343

3.608

LIMLHGR, KW/ft

10.756

10.719

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Findings

The precedure SP 1041 requires that fuel bundles exposed to

more than 23,500 MWD /T in average, be identified from the on-

demand computer program 0D-10, option 24. The procedure further

requires that the Maximum Average Nodal Exposure, its MAPLHGR

and LIMLHGR be calculated for the identified bundles from tha

0D-6, Option 2, to ensure that the maximum nodal exposure is less

than 30,000 MWD /T and that the thermal hydraulic parameters

are within the limits.

It also requires that the computer

calculations are summarized onto the RE Form 1041-1.

The inspector identified the following deficiencies for the

test performed June 26, 1981:

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Test package file did not have the on-demand program output

of 00-10, option 24, as required by the procedure SP 1041.

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Incorrect MAPLHGR and LIMLHGR were recorded. The correct

values for 03-16-08 bundle should be 3.343 KW/ft and

10.756 KW/ft respectively, instead of 3.484 and 10.891

KW/ft as entered on the data sheet.

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Shift Supervisor and Department Head who reviewed the data

failed to recognize the errors.

The above failures to document and to properly review the test

results constitute an example of noncompliance summarized in

section 4.

(8) Calibration of Intermediate Range Monitors (IRM)

The inspector verified that IRM readings were calibrated against

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Average Power Range Monitor (APRM) readings on April 19,.1981,.

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in accordance with procedure SP 1055, IRM Calibration

Data, Revision 1, September 24, 1979.

The test results showed

9% differer.ce between IRM and APRM readings at 15.5% core thermal

power. Subsequent IRM corrective calibrations were performed

April 27, 1981, using SP 402C, IRM Calibration Test, Revision 4,

June 18, 1980.

Findings

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The inspector noted that the acceptance criteria were not

specified in the procedure SP 1055, and the corrective calibration

was not cross-referenced in the test package, even though the

excessiva deviation between IRM and APRM readings were recognized

and a subsequent corrective. calibration was performed April 27, 1981.

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The above findings constitute an example of noncompliance

summarized in section 4.

9) local Power Range Monitors (LPRM) Calibration

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The inspector verified that LPRM calibration and gain adjustment

were performed June 24, 1981, in accordance with the procedure

RE 1003, Revision 3, July 1,1977.

The inspector had no further questions.

(10) Core Thermal Power

The inspector verified that APRM's were calibrated as per

procedure SP 1040, APRM Calibration Using Heat Balance, Revision 1,

May 4, 1979. The calibration / gain adjustment factors reviewed

were the test data performed July 2, 10, 17, 31, and June 21,

1981.

The core thermal power was measured using procedure RE 1002,

Core Heat Balance - Power Range, Revision 7, June 18, 1980.

Core thermal power calculations by different methods were in

good agreement as shown in the following:

Method

Core Thermal Power, MW

t

Hand Calculations

2005.54

P-4*

2004.10

00-3*

2000.53

  • P-4 is based on a 10 minute interval and 0D-3 is an

instantaneous heat balance calcula.tton.

The inspector had no further questions.

4.

Noncompliance

The inspector identified one item of noncompliance in the activities and

procedures related to

quality and

safety:

Failure to provide

adequate instructions and acceptance criteria for procedures; to properly

review and document the test results; and to follow written procedures.

Appendix B, Part 50, 10 CFR, specifies requirements for the activities

affecting quality'in that:

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Criterion V, " Instructions, Procedures, and Drawings," requires such

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activities be prescribed by procedures and be accomplished in

accordance with the instructions or procedures, and further requires

that the instructions or procedures shall include appropriate

quantitative or qualitative acceptance criteria for determining

satisfactory accomplishment of the activities.

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Criterion XI, " Test Control," specifies that all testing be performed

in accordance with the written procedures, which include the require-

ments and the acceptance limits contained in applicable design

documents. The criterion further requires that test results be

documented and evaluated to assure that test requirements have been

satisfied.

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Criterion XVI, " Corrective Action," requires to identify

malfunctions, deficiencies, and defective equipment, and to correct

the adverse conditions promptly. The criterion further specifies that

the corrective action shall be documented.

Criterion XVII, " Quality Assurance Records," requires that test

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records include, among others, the results, the acceptability, and

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action taken in connection with deficiencies noted. Also, the records

shall be identifiable and retrievable.

Contrary to the above, the following examples of findings were identified

as detailed in 2.b(1), 3.b(1), 3.b(2), 4.b(4), 4.b(5), and 4.b(6):

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Details in item 2.b(1): Average scram insertion times for test

performed April 19, 1981 were not calculated and entered as per

procedure SP 1051 and RE Form 1051-3; ' there was no objective evidence

of documentation in the package that corrective action was taken as

per Technical Specification 3.3.C when the test performed April 19,

1981 failed.

The Replacement Job Order number was not documented in

the test package.

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Details in item 3.b(ll:

Procedure SP 690B and Operations Form 6908-1

did not provide sufficient information or references to conduct the

test calculations of SDM; formula in step 7.4.5 of Operations Form

6908-1 was incorrect; consequently, the SDM calculated on April 17,

1981 was incorrect.

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Details in item 3.b(2):

Reactor period was not entered in the data

sheet, SP Form 1050-1, during the test performed June 29, 1981;

Procedure SP 1050 and the associated data form did not provide

sufficient data reduction details, references, and acceptance

criteria.

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Details in item 3.b(6):

Reactor Engineering Proceuure RE 1057 did not

have acceptance criteria or references; documents for the verification

test conducted on April 16, 1981 did not have any objective evidence

that the input parameters were verified against the figures in Technical Specifications 3.11.1.

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Details in item 4.b(7):

The on-demand program outputs 00-10, option

24, for June 26, 1981 had not been documented as required by the

procedure SP 1041;

incorrect fuel parameters were recorded in RE Form

1041-1 for the test performed June 26, 1981; reviewers failed to

recognize the errors.

Details in i; tem 3.b(8): Acceptance criteria were not provided in the

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procedure SP 1055; corrective calibration performed April 27, 1981 was

not identitled in the test packages, in which the deficiency was

identified.

The licensee representative stated that proper remedial steps would be

taken to correct the above findings, and the necessary procedure revisions

would be completed prior to September 1, 1982.

The above failures to meet the requirements specified in the Code of Federal

Regulations, Appendix B to 10 CFR 50, Criteria V, XI, XVI, and XVII, collect-

ively constitute an item of noncompliance (50-245/81-13-01).

5.

Post Refueling Startup Test Review

a.

The inspector reviewed the Cycle 8, Startup Book, April 15, 1980, to

verify that:

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Test sequence was consistent with the requirements;

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Testing was conducted in accordance with the sequencing Startup

Book;

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Sequencing Startup Book was properly reviewed and documented;

and

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The startup report was issued.

b.

The inspector noted, during the review of the Cycle 8 Startup Book,

+ hat the final review of the test results was not completed. A licensee

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representative stated that as soon as the departmental reviews were

completed, the Startup Book would be signed off and be reviewed by

Plant Operations Review Committee (PORC). The unreviewed tests were:

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Hot TIP alignment

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Jet pump baseline data

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TIP asymmetry check

The Cycle 8 startup test summary report was not yet av:ilable, and

the inspector was informed that the summary report would be submitted

to NRC shortly as required by Technical Specifications.

No unacceptable conditions were identified.

6.

Control Room Observations and Facility Tours

The inspector observed Control Room Operation for shift turnover and log

sheets, and facility operation in accordance with the administrative

procedures and Technical Specification requirements.

Inspection tours of

the Reactor Vessel penetrations and pipings to and from the Isolation

Condenser were conducted to visually observe the evidence of movements of

the pipings and the support structures caused by the recent water hammer.

The inspector noted that the several bolts holding the piping supports to

the concrete floor for the isolation condenser had been lifted up to 1/8",

possibly due to the impa-t forces. The inspector did not find any

permanent structural da....ges from apparent piping movements. The inspector

discussed the observations and the concerns with the resident inspectors.

The inspector had no further questions.

7.

Entrance and Exit Interviews

Licensee management was informed of the purpose and scope of the inspection

at the entrance interview, and the findings of the inspection were

periodically discussed and were summarized at the conclusion of the

inspection on August 14, 1981. Attendees at the exit interview are denoted

in paragraph 1.

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