ML20032D657
| ML20032D657 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 11/06/1981 |
| From: | Hopkins J, Jackiw I, Lanksbury R, Maura F, Peschel J, Ring M, Robinson D, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20032D653 | List: |
| References | |
| 50-373-81-28, NUDOCS 8111170361 | |
| Download: ML20032D657 (16) | |
See also: IR 05000373/1981028
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-373/81-28
Docket No. 50-373
License No. CPPR-99
Liceraee: Commonwealth Edison Company
P. O. Box 767
Chicago, IL 60690
Facility Name: La Salle County Station, Unit 1
Inspection At: La Salle Site, Marseilles, IL
Inspection Conducted: August 11, 12, 17-21, 25-28, September 1-4, 8-11,
15-18, and October 8, 1981
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Inspectors:
F. M ura (August 17-20. 25-28,
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September 8-11, 17, 18, and October 8)
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September 11)
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August. 26, 27, September 3,
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gust 18-21, 25-27
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and September 17-18)
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Approved By:
I. N; Jackiw Acting Chief
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8111170361 811106
gDRADOCK 05000373
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Inspection Summary
Inspection on August 11, 12, 17-21, 25-28, September 1-4, 8-11, 15-18,
and October 8, 1981 (Report No. 50-373/81-28)
Areas Inspected: Routine, unannounced inspection to review preoperational
test procedures and results, startup program test procedures review, pre-
vious open items and material traceability of piping in selected systems.
The inspection involved 464 inspector-hours on site by eight NRC inspectors
including 30 inspector-hours onsite during offshifts.
In addition, the
inspection involved 490 inspector-hours of inspection effort at the regional
of fice by five NRC inspectors.
Results: Of the five areas inspected no items of noncoapliance were iden-
tified in two areas. Within the three remaining areas five apparent items
of noncompliance were identified (failure to conduct proper evaluations
and reviews of test results - Paragraphs 3.a., 3.b., 3.d.; failure to
ensure pipe meets FSAR design requirement - Paragraph 8.a.; failure to
maintain material traceability records - Paragraph 8.b.; failure to control
work done on drywell liner - Paragraph 7. ; failure to control a design
document - Paragraph 3.e.).
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DETAILS
1.
Persons Contacted
- B. Stephenson, Project Manager
- R. Holyoak, Station Superintendent
- L. De1 George, Licensing Administrator
- H. Morris, Engineer, Project Engineering
- T. Watts, SNED Project Engineer
- R. Bishop, Assistant Superintendent
J. Coonan, Assistant Superintendent, Maintenance
- W. Huntington, Assistant Technical Staff Supervisor
E. Pfister, Lead Nuclear Engineer
- R. Rose, Lead Structural Engineer, Construction
J. Harchut, Engineer, Construction
- D. Skoza, Engineer, Construction
- D. Shamblin, Engineer, Project Management
- T. Quaka, Construction QA Superintendent
- R. Braun, Construction QA Supervisor
- R. Kyrouac, Operations QA Supervisor
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M. Wherry, QA Supervisor, Morrison Co.
R. Turkowski, GE Lead STD & A Engineer
Sargent and Lundy Engineers, Inc.
- A. Walser
- V.
Reklaitis
- R.
Cheboub
The inspectors also interviewed other licensee employees including
members of the construction, quality assurance, technical and operat-
ing staff and employees of Morrison Co., Foley Co. and Zack Co.
- Denotes those attending the exit interview of September 18, 1981.
- Denotes those attending the exit interview of October 8, 1981.
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- Denotes those attending the exit interview of September 18 and the
meeting of October 8, 1981.
2.
Licensee Action on Previous Inspection Findings
(Closed) Noncompliance (373/80-36-02) and Unresolved Item (373/80-
15-09) Failure to centrol motor operated valve torque switch settings.
The inspector verified that the licensee issued a revised motor
operated valve torqee switch setting list and that the Station Nuclear
Engineering Department (SNED) by letter dated November 25, 1980
defined how the list was to be used. Additional instructions were
issued by SNED on June 16, 1981.
(Closed) Open Item (373/80-15-08) Foreign material in reactor vessel
and internals. The inspector reviewed NCR li415, closed on March 11,
1981, and determined that the licensee completed the cleaning of the
steam separator assembly.
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(Closed) Open Item (373/80-25-06) Missing cable termination card.
The inspector verified that Foley Electrical Co. generated a "to"
termination card for cable number 158 on August 5,1981. According
to Foley's QA Supervisor the field terminations were verified in
November, 1978.
(Closed) Open Item (373/80-25-12) High pressure bypass leakage
preoperational test. Amendment No. 54 to the FSAR reclarified the
high pressure bypass leakage test as a construction test.
(Closed) Open Item (373/78-33-02)
ILRT performance with liner channel
plugs installed. The inspector informed the licensee that NRC's
position was that the ILRT had to be performed with the liner channel
plugs remcVed or an exemption obtained from NRR. On September 1 and
October 1,1981, the licensee submitted their justification for not
venting the liner channels to NRR.
(Closed) Open Item (373/80-49-01) Air leak rate testing of certain
ECCS penetrations. The inspector verified that the licensee has
revised PT-PC-101 to air test all the penetrations which could
lose their water teal during a postulated LOCA with loss of offsite
power and the fa2 Wre of their ESF division diesel generator.
(Closed) Otem Item (373/80-49-03) PT-PC-101 summary sheets did not
include several ECCS penetrations being air tested. The inspector
verified that Rev.
23 to PT-PC-101 revised Data Sheets 12.11 and
12.13 to include all ECCS penetrations being air tested.
(Closed) Open Item (373/81-20-07) Margin load test for diesel
generator 2A. The inspector reviewed the Unit 2 loads required for
Unit I operation and determined that a margin load test is not re-
quired at this time. For Unit 1 operation the total load is approxi-
mately 15% of rated and the largest single load is approximately 10%
of rated.
(Closed) Open Items (373/79-37-01 and 02)
Incorporation of additional
acceptance criteria on STP-5, CRD System to correspond with prototype
testing results of the new thin blades. The licensee and the General
Electric Company have taken the position that additional criteria is
not necessary, that they were added to the Zimmer program to demon-
strate the adequacy of the original test program. The inspector
stated that he will review the test results against the criteria
developed for Zimmer which is based on prototype test results.
(Closed) Open Item (373/80-36-03) The item involved test procedure
SD-WE-101E (Sump Monitoring) not specifying acceptance criteria con-
sistent with the proposed technical specification limits. The
inspector determined that consistent acceptance criteria are now
specified in the test procedure.
(0 pen) Open Item (373/81-07-03) This item dealt with how test pro-
cedure PT-IN-101 (Primary Containment Instrument Air) satisfied
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Section C.4 of Regulatory Guide 1.80 relating to flow and temperature
of the product ain. The licensee stated that no further actions
had yet been taken on this item. The item remains open pending
further discussions with the licensee.
(Closed) Open Item (373/79-06-03) This item dealt with ensuring
that true specific gravity readings are monitored during battery
surveillance by correcting for electrolyte level changes. The
inspector reviewed surveillance procedure LOS-DC-Q2 Revision 0,
Charging Requirements and Battery Readings for Safety Related
250 V DC and 125 V DC Batteries, dated July 21, 1981 and determined
that electrolyte level readings are recorded and subsequent specific
gravity corrections are provided.
(Closed) Unresolved item (373/78-23-01) This item dealt with PT-AP-102
failing to demonstrate that the battery chargers can recharge their
respective Division 1 or 2 batteries within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> while supplying
normal plant D.C. loads. 1.dditionilly, the Division three hattery
charger (HPCS) was not demonstrated to recharge from minimum to fully
charged while carrying maximum steady state loads within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The licensee has since demonstrated and defined fully charged and
normal loads. The time frame of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> has been deleted from the
FSAR paragraph 8.3.2.1.1 which now reads "a time commensurate with
the recommendations of the battery vendor." The SER (Safety Evalua-
tion Report), however, still expected the recharge to occur within
the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time frame. The Division three battery charger has been
moved to another procedure which has been revised to incorporate the
above requirements. Discussion with NRR (J. Knox) indicates the 12
hour time frame in the SER is no longer applicable.
(Closed) Noncompliance (373/81-22-19): Failure to use an approved
procedure while performing maintenance. The inspector found that
the Work Request in question has received a review, and a procedure
containing applicable portions of the vendor's manual was written
and approved in accordance with Figure 9 of the Station Quality
Assurance Manual. Maintenance personnel have been instructed to
submit procedures containing the applicable portions of the vendor's
manual for on site review.
(Closed) Noncompliance (373/81-22-20): Failure to write a Deficiency
Report. The inspector found that Deficiency Reports were written for
the identified condition. Engineers involved in testing have been
instructed by the Project Manager of the need to document deficient
conditions with a Deficiency Report.
(Closed) Unresolved Item (373/81-22-21): Failure to implement a
Preventive Maintenance Program. The licencee has issued LAP-300-8,
Rev.
O,9/81. Preventive Maintenance Program. The inspector found
the references contained in LAP-300-8 were available and the program
was being implemented.
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(0 pen) Unresolved Item (373/81-22-22): Failure to implement a
Housekeeping and Fluid System Cleanliness Program. The inspector
found that LAP-300-16, Rev.
O, 9/81, Cleanliness Control, has been
issued and appears to meet industry standards, however, LAP-900-15,
Rev. 4, September 1981, Housekeeping Practices, does not meet industry
standards for maintenance activities occurring during the operational
phase which are comparable i nature and extent to related activities
occurring during construction. The licensee stated that LAP-900-15,
Rev. 5 was in the review pt- -ss and it would meet the industry standards.
(0 pen) Unresolved Item (373/. -22-23): Failure to establish a "Q list".
The inspector found that the t'censee had not established a list covering
all activities addressed by tl' QA program, nor has he defined how the
program will be applied to the non-safety-related/ASME Section III
Activities. The licensee stated that a procedure or guideline would
be developed defining how to determine what is on the Q list and de-
fining to what extent the QA program will be applied to the non-
safety-related/ASME Section III Activities listed in Quality Require-
ment 2.
(0 pen) Unresolved Item (373/81-20-10): Failure to verify diode
integrity. The inspector found that LES-DG-101 has been changed to
require a yearly verification of blocking diode integrity, but there
is no procedure referenced to describe the verification process. The
licensee stated that a repair manual will be written to provide a
procedure for diode verification.
(0 pen) Unresolved Item (373/81-20-11): Failure to refurbish the diesel
generator crankcase pressure switch on a periodic basis. The inspector
found that the licensee has not revised the surveillance procedure to
include the crankcase pressure switch.
(0 pen) Unresolved Item (373/81-20-15): Failure to provide for re-
furbishing diesel generator air start motors no later than every 50
starts. The inspector found that a surveillance procedure that will
monitor diesel starts and call for start motor refurbishment has been
drafted, however, it has not been incorporated as part of the surveil-
lance program.
3.
Review of Preoperational Test Procedures and Test Results
The inspectors reviewed the following test procedures and test
results against the FSAR, the SER, Regulatory Guide 1.68, and the
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QA Manual and found them satisfactory unless otherwise noted.
Deficiences which remain unresolved cust be reviewed by QA prior to
system release for operation.
At that time, all items which must be
corrected prior to fuel loading will be identified. Open items
covering the inspector review of the corrective actions taken by the
licensee appear with each preop test listed below.
a.
PT-SC-101, Standby Liquid Control System and SD-PS-101, Process
Sampling System.
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(1) FSAR Table 14.2-54 Test Procedure Item No. 5 states that
upon completion of all previously stated tests, the standby
liquid control tank is filled with the required boron solu-
tion, mixed and sampled and that this will be accomplished
just prior to fuel loading. A:ceptance criteria-#7 states
that " liquid mixing results in a uniform solution and
samples are rep *2sentative of storage tank liquid." The
test procedure did not require testing to ensure that the
air sparging sub-system could promote adequate mixing to
satisfy this cammitment.
A review of the test results in the completed procedure
indicated that the station and the station nuclear engineer-
ing department (SNED) initial review of the procedure had
failed to note that this commitment had not been met and
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thus a deficiency had not been generated as required by
LSU 200-2, to allow tracking of the commitment to ensure
its performance prior to fuel load. A later review by
SNED did note that this commitment had not been performed,
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however, SNED failed to adequately ensure that the station
was tracking this commitment.
The inspector reviewed an unofficial draft of a master
pre-fuel load checklist that was being used by the station
to track the above commitment and concluded that the item
identified on the checklist by the station does not meet
the acceptance criteria of the FSAR but instead only
ensures that the technical specification requirements are
met.
(2) FSAR Table 14.2-71 Test Procedure Item No. 4 states that
a verification will be made that all sensors in the pro-
cess sampling system are properly located in accordance
with design. The test procedure did not specifically
require this verification be made to ensure that data
taken by the licensee to evaluate actual chemistry con-
ditions to technical specification limits was valid and
to satisfy this commitment.
The licensee contended that this commitment was met by the
test engineer walking down the system, as required by stat -
lon procedure LSU 100-2; however, a review of this procedure
by the inspector revealed that it has no specific require-
ment to. verify system components are correctly located.
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In addition, the preoperational test procedure did not
reference this procedure, so no documentation existed in
the test package that the FSAR commitment had been met.
The above two items are considered to be violations of
10 CFR 50, Appendix B, Criterion V and XI, and are an
example of an item of noncompliance (373/81-28-01A).
(3) Open Item (373/81-28-02) Unresolved deficiencies, PT-SC-101.
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Open Item (373/81-28-03) Unresolved deficiencies, SD-PS-101.
b.
PT-NB-101, Nuclear Boiler System
(1) A review of the test results in the completed procedu.4
and the test evaluation indicated that the station and
the station nuclear engineering department (SNED) had not
noted, nor evaluated during their reviews the following
dir4repancies:
(a) the test data showed that the level
3 (12.5" above instrument zero) scran trip switches and
ADS permissive switches reset at a lower value than the
what they tripped at, (b) some of the level 8 (55.5" above
instrument zero) RCIC turbine and HPCS injection valve
closure trip switches reset at a higher value than the value
they tripped at, (c) that one of the level 2 (-50" below
instrument zero) HPCS initiation and Division 3 diesel
generator start switches reset at a lower value than the
value it tripped at.
This is one of the ten procedures
that was re-reviewed by SNED in response to a previous
item of noncompliance (Report No. 373/81-20).
Based on subsequent investigation by the licensee and the
inspector, including discussion with the switch vendor and
General Electric and review of the most recent calibration
sheets, it was concluded that the problem appears to not
be with the switches but may be caused by the testing method.
The licensee was requested by the inspector to make a com-
plete evaluation of the problem and determine if any further
testing is required.
The above item is considered to be a violation of 10 CFR 50,
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Appendix B, Criterion XI, and is an example of an item of
noncompliance (373/81-28-01B).
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(2) Open Item (373/81-28-04) Unresolved deficiences, PT-NB-101.
c.
SD-SA-101, Service and Instrumene Air System
(1) FSAR Section 9.3.1.2.1 states that the design of each air
compressor is such that its capacity is 1750 SCFM at 115
psig discharge pressure. The test procedure required the
measuring of the time it took the air compressor to pump air
into its air resovoir from a discharge pressure of 90 psiF
to 110 psig and then using this determination to figure the
capacity of the compressor.
The test evaluation failed to show that the calculated
capacity, (which is greater than 1750 SCFM, as measured
at a discharge pressure of between 90 and 110 psig) is
equal to or greater than the design capacity specified
in the FSAR. The inspector has requested that the licensee
evaluate the data and determine that the air compressors'
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capacity at a discharge pressure of 115 psig is in accord-
ance with the FSAR requiren.ents. This is considered an
Unresolved Item (373/81-28-05) pending receipt of the above
requested data.
(2) Open Item (373/81-28-06) Unresolved deficiencies SD-SA-101.
d.
PT-VP-104, Primary Containment Chilled Water, and
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PT-VP-101, Primary Containment Vent and Purge
(1) The licensee has issued a tabulation of Motor Operated
Valve switch settings entitled " Motor Operator Data" and
via letter, T.E. Watts to R. H. Holyoak dated November 25,
1980, stated that "all safety-related motor operated valve
torque switch settings must be within the range indicated
in the " Motor Operator Data" list dated October 29, 1980.
The test engineer's evaluation of PT-VP-101 on page 32
attempted to update the switch settings to match the list.
However, four valves IVQ034, IVQ041, IVQ042 and IVQ043
were done incorrectly resulting in incorrect switch sett-
ings on the valves. Failure to correctly specify the
torque switch settings is considered to be a violation
of 10 CFR 50 Appendix B, Criterion V and is considered to
be an item of noncompliance (373/81-28-01C).
(2) The inspector questioned the torque wrench method of
verifying proper opening set points for the vacuum breaker
valves in PT-VP-101. Review of the torque values specified
and their method of application was not complete as of
this inspection. This item is an unresolved item (373/81-
28-07) pending completion of the review.
(3) Open item (373/81-28-08) Unresolved deficiencies PT-VP-101.
(4) Open Item (373/81-28-09) Unresolved deficiencies PT-VP-104.
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e.
PT-VP-202, Post LOCA H Control
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(1) During the performance of PT-VP-202, Post LOCA H Control,
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the test engineer identified 3 valves; 2HG-MV-10, 2HG-FV-1
and 2HG-FV-2 whose torque switch settings were not listed
in the Motor Operator Data book and kept. in Central File.
Follcwing identification of the problem, the resolution was
to set the valves to the same settings as the identical Unit
I valves. The torque switch settings for these valves were
also not in the Motor Operator Data book, however, their
settings had been previously taken from name plate data.
The original deficiency had been identified and cleared,
test procedure PT-VP-202 had been performed and its results
had been reviewed in May 1981. The inspector reviewed the
procedure and the. Motor Operator Dat.a book on September 11,
1981 and noted that the Motor Operator Data book had not
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been updated to reflect the missing valves. No open de-
ficiency existed at the site to indicate that the book was
incomplete. Additionally, three valves, 2HG018, 2HG002-A,
and 2HG002B, were noted, by the test engineer to have con-
flicting settings between the Motor Operator Data book and
the name plate data. The SNED response to the deficiency
stated that the valves should be set to the name plate data
and that the Motor Operator Data book should be changed.
As of the inspector's review on September 11, 1981, the
Motor Operator Data book had not 1.een changed and no docu-
mented deficiency existed at the site indicating the book
was incorrect. The above examples show a failure to provide
adequate controls for a document which prescribes activities
affecting quality. This is considered to be a violation of
10 CFR 50, Appendix B, Criterion VI and is considered to be
an item of noncompliance (373/81-28-10).
(2) Cpen Item (373/81-28-11) Unresolved deficiencies PT-VP-202.
f.
PT-RD-101B Rod Sequence Control. Unresolved deficienies, Open
Item (373/81-28-12).
g.
PT-RD-101A, Rod Drive Control and Rod Position Indication.
Unresolved deficiencies, Open Item (373/81-28-13).
h.
PT-VD-101, Diesel Ventilation, Unit 1.
Unresolved deficiencies,
Open Item (373/81-28-14).
i.
PT-VD-201. Piene'; Ventilation, Unit 2, Unresolved deficiencies,
Open Item (373/81-28-15).
J.
PT-VY-201, CSCS Equipment Cooling, Unit 2.
Unresolved deficiencies,
Open Item (373/81-28-16).
h.
SD-FC-101, Fuel Pool Cleanup. Unresolved deficiencies,
Open Item (373/81-28-17).
1.
SD-HD-101A, Heater Drain. Unresolved deficiencies,
Open Item (373/81-28-18).
n.
SD-HD-101B, Moisture Separators and Reheaters. Unresolved
deficiencies, Open Item (373/81-28-19).
o.
SD-CX-102, Rod Worth Minimizer. Unresolved deficiencies,
Open Item (373/81-28-20).
4.
Preoperational Test Results Review
The inspector reviewed the results of completed test procedures
PT-AP-102 and PT-AP-202 D.C. Distribution for Units 1 and 2 re-
spectively. For PT-AP-202, only the portion required to support
the Unit I fuel load was reviewed. The following problems were
noted:
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a.
Paragraph- 10.3.B.2.c of PT-AP-102 250 V Battery No I requires
that the individual cell voltage, specific gravity and temperature
.of each cell and the bus voltage be recorded on Data Sheet 12.1d.
Instead, the licensee recorded every 6th cell temperature. No
procedure change was made and the discrepancy was not noted in
the evaluation.
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b.
During the 24 V Battery acceptance tests for all four batteries,
paragraph 10.3.G.2.g (and similar paragraphs for the remaining
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batteries) required that cell voltage reading be taken hourly
for the first three hours of the discharge and then every 15
minutes until the end of the discharge. The' inspector noted that'
data sheets 12.4e, f, g, and h, were issued with a one half hour
gap between 3 and 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.
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These items are considered to be violations of 10 CFR 50,
Appendix B, Criterio XI and V and are examples of noncompliance
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(373/81-28-01D).
The inspectors also noted that page 8-16 of the SER states the
following:
"Each Division 1 and 2 battery charger as well as
each high pressure core spray (Division 3) battery charger has
sufficient capacity to restore its battery to full charge under
the maximum steady-state load." Page B 1-39 of the FSAR describ-
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ing the licensee's commitment to Regulatory Guide 1.32 was revised
by Amendment 55 dated March 1981 to state the same cords as
quoted above from the SER. The licensee's procedure demonstrates
the capability to recharge the battery under normal loads but
not under "rcaximum steady state loads." The licensee contenas
that, the statement on page B 1-39 only describes the battery
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chargers capability and not what oney would be required to do
{
by test.
NRR (J. Knox) concurs with the licensee's position.
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5.
Preoperational Test Procedure Verification
The inspectors verified that the following preoperational test
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procedures appear to meet the requirements of Section 14 of the FSAR,
and were reviewed, and approved by licensee management in accordance
with the requirements of Regulatory Guide 1.68 and the licensee's QA
Manual, unless noted otherwise:
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a.
PT-MS-101B, Mainsteam Isolation Valves and Instruments.
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b.
PT-MS-101A, MSIV Leakage Control System.
c.
PT-VP-104, Primary Containment Chilled Water
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d.
PT+VD-101, Diesel Ventilation
e.
PT-VE-101, Auxiliary Electrical Equipment Room HVAC.
f.
PT-VJ-101, Machine Shop HVAC.
g.
PT-VL-101, Laboratory HVAC.
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h.
FT-V0-101, Off-Gas Building HVAC.
i.
PT-VP-103, Primary Containment HVAC.
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PT-VP-102, Post LOCA Hydrogen Control.
k.
PT-VC>101, Control Room HVAC.
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The procedure did not verify air flow through all personnel
access points is out leakage rather than in leakage as required
by table 14.2-17 of the FSAR. This utficiency had been pre-
viously identified by the licensee and is still open as a pro-
cedure deficiency. This deficiency is an open item (373/81-28-21)
pending the addition of the verification to the procedure.
1.
PT-ST-102, " Vibration Monitoring Preoperational Tests"
FSAR Table 14.2-16, Test Procedure Item No. 2, states in part
that the inspection for visually perceivable vibration includes
branch piping from the main flow paths greater than two inches
in diameter. The test procedure requires looking at branch
piping greater than two inches in diameter, up to the first
support, for visually perceivable vibration.
If vibration is
noted then the remainder of the branch piping will be inspected.
The inspector has questioned whether the licensee's test pro-
cedure meets the FSAR commitment since the FSAR implies that all
branch piping will be inspected and not just the branch piping
up to the first support. This is considered an Open Item
(373/81-28-22) pending further review by Region III technical
inspectors.
m.
PT-CM-101, Containment Monitoring Preoperational Test.
FSAR Table 14.2-7, Test Objective item No. 1.f. states that one
of the parameters to be tested is suppression pool bulk water
temperature. The test procedure does not currently contain
any provision for testing this parameter. The licensee is
currently pursuing a technical specification change and upon
approval of this change plans to submit a FSAR change to
delete the requirement for testing the suppression pool bulk
water temperature. This is considered an Open Item (373/81-
28-23) pending resolution by the licensee and review by the
inspector.
n.
PT-HC-101, Reactor Building Crane
o.
PT-VX-101, Switchgear lleat Removal System
p.
PT-RA-101, Reactor Protection System
q.
PT-RP-102, Remote Shutdown System
r.
PT-VW-101, Radwaste Area HVAC System
s.
PT-PC-103, Primary Containment Isolation System
t.
SD-CQ-101, Communications System
u.
SD-EH-101A, Turbine Electrohydraulic Control System
6.
Review of Startup Program Test Procedures
The following startup program test procedures were reviewed and
found to meet the requirements of the FSAR, 3ER, Regulatory Guide 1.68, and the licensees QA Manual:
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'
.
a.
STP-3, Fuel Loading
b.
STP-4, Full Core Shutdown Margin
c.
STP-11, LPRM Calibration
d.
STP-12, APRM Calibration
e.
STE-13, Process Computer
f.
STP-18, Core Power Distribution
g.
STP-19, Core Performance
h.
STP-1, Chemical and Radiological (review consisted of the
water chemistry portion only)
i.
STP-14, RCIC. The licensee had not incorporated the vendor's
comments at the time of the inspection. This item remains open
(373/81-28-24) pending the incorporation of GE's comments.
j.
STP-16, Process Temperature
k.
SIP-70, Reactor Water Cleanup
1.
STP-71, RER
7.
Containment Liner
A major portion of the containment drywell liner was inspected in the
company of licensee representatives.
Items of concern were identified
and their location recorded. They included liner plate bulges, weld
burn marks, undercuts, and " temporary brackets. Neither the licensee
nor its subcontractors could produce documentation to demonstrate
that the " temporary" work done against the liner had been controlled.
All four subcontractors denied responsibility for any of the brackets
welded on the liner. Failure to control the welding of " temporary"
brackets to the containment liner through the use of drawings
and/or procedures to identify their location, purpose, etc. , and
their correct disposition is considered to be a violation of
10 CFR 50, Appendix B, Criterions V and IX and the QA Manual,
Quality Requirements 5.0 and 9.0 and is an example of an item of
noncompliance (373/81-28-
T.
Among the items identifie
ce nine areas where the liner had
bulged inwards.
In most
.s the bulges appear to have been plate
distortions generated dur
, the initial construction of the liner.
The peak radial deflectior is in the range of 1/2" to 1".
While no
attempt was made to determine their volume the surface area of the
bulges is estimated to range between 150 to 400 square inches. All
bulged areas sounded as though they were not backed by concrete when
l
struck with a hammer. They sounded hollow. The adjacent areas of
the liner sounded like they were backed by concrete. The extent of
the apparent " voids" associated with the apparently buldged area of
r
the liner could not be determined. The licensee was asked to deter-
mine if:
a.
the existance of the buldged and apparently unbonded to concrete
area are acceptable during a LOCA,
b.
there are any detrimental long term effects caused by periodic
CILRT,
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,
.
-
.
c.
if the buldged and unbonded area are associated with any possible
concrete imperfections
d.
the noted buidges traverse areas of the liner defined by the
location of the liner plate concrete L anchors, which could
indicate separation of an L anchor from the liner plate. The
inspectors noted that one buldged area involved the apparent
location of a liner concrete L anchor.
Meetings on this subject were held un October 1 and 8, 1981, becween
Region III personnel and members of the licensee's staff. During
the meeting on October 8, 1981, the licensee stated that based on
an engineering evaluaticu of the containment liner deformations
(conducted by CECO and SJL engineers), it was concluded that the
liner met all the design criteria and was structurally sound. The
licensee and their engineering contractor also stated that the
deformations were results of welding of the embedments and that the
,
structural integrity test did not cause any outward deformations,
therefore no voids of any significant magnitude can exist.
At the conclusion of the October 8, 1981 meeting the licensee was
'
requested to document their conclusion and send a report of their
engineering evaluation to Region III.
It was requested that the
report include:
a.
Identification and categorization of the deformations on the
liner and specifically those deform, tions that span over two
anchors,
b.
Any surveillance program the licensee plans to initiate to mor.itor
the condition of the deformations, and,
c.
All empirical data to support the cenclusion that with the
deformatior_, the integrity of the containment liner has not
been compromised and also that the concrete behind these
deformations is free of imperfection.
This is an open item (373/81-28-26) pending review of the licensee's
actions.
8.
Containment Leak Rate Tests
The licensee plans to perform the containment integrated leak tests
after fuel loading, but prior to operation requiring containment
integritr, using the surveillance procedure developed for periodic
ILRTs'. The licenst.e stated that Pa is being recalculated and the
results will not bc v.ailable until October at the earliest. The
inspector stated that:
a.
If the new calculated Pa exceeds the pcessure at which the
November 1980 test was conducted, the origina. preoperational
test will be considered invalid.
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t
.
b.
Region III has no objection to the test being performed after
fuel loading and prior to containment intergrity requirement
provided the licensee keeps NRR informed and obtains a waiver
from any FSAR requirements. Additionally, the preop must be
performed prior to fuel loading, if the original test becomes
invalid.
9.
Component Traceability
The inspectors conducted an audit of piping in the 1 B diesel
generator air start system, the standby liquid control system,
control rod drive system and drywell pneumatic system. The
findings were as follows:
a.
Lines 1 HP 77 AB 2 and 1 HP 77 AA 2 which connect air receiver
tanks A, B, C, and D to the 1 B diesel air start motors were
inspected. No identification numbers, other than at fittings,
could be located.
In most cases the line had been painted,
however a few sections of new pipe remained unpainted. The
.
licensee was asked why the unpainted sections of pipe had no
merkings and to what code it had been built.
In response to
the inspectors inquiry the licensee reviewed the auxiliary
systems for the two General Electric supplied diesel generators
and determined that while piping supplied by the manufacturer
as an integral part of the diesel package did not have to meet
ASME Section III-1074 requirements, all changes made by CECO
had to meet those requirements. As a result, NCR No. 538 was
written to replace 20 sections of pipe within the starting air,
cooling water, and fuel systems of diesel generators 1 B and 2 B
in order to comply with the requirements of Table 3.2-1 of the
FSAR.
Failure to podify sections of the two HPCS diesel generators
system in accordance with FSAR Table 3.2-1 is considered to be
a violation of 10 CFR 50, Appendix B, Criterion III and the
Q. A. Manual, Quality Requirement 3.0 and is an example of
an item of noncompliance (373/81-23-27).
b.
Approximately ont third of lines 1 SC 02 AA 1 1/2 and
1 SC 08 AA 3/4, frca the SLCS pump 1 A to the explosive valve,
was inspected. A section of pipe between welds WSC-45 and 46
was found to be marked with heat number B 2155 while LLe as
built drawings indicated the heat number to be 70362. The
inspector determined that both heat numbers were acceptable;
however, the licensee was requested to determine why correct
traceability had not been maintained. The licensee performed
an audit of approximately 70 components (pipes and fittings)
within the same two lines and determined that a total nf five
code cr heat numbers were incorrect. They included two sections
of pipe, one elbow, ore. flange and hex nuts. According to the
licensee the problem appears to be a cocumentation transfer
error, which occurred when the informe: tion was transferred from
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.~
_
_
,
1
.
,
e
the " cut sheet" (generated at the time the material is selected)
to the isometric drawing Bill of Materials list. The errors
were corrected in revision M to isometric Dwg. F-SC-1201.
At
the inspector's request the licensee performed an audit of
additional piping in the SLCS above elevation 820' which in-
volved over 150 components in eleven isometric drawings. No
additional errors sere found.
c.
A section of pipe in the drywell pneumatic system isometric
drawing No. IN-215 was found by the inspector to contain two
heat numbers, 745333 (engraved) and 783234 (stenciled). A
review of the material certification records showed both heat
numbers to be acceptable. The licensee corrected the error
by removing the engraved number (745333) and engraving the
correct number 783234.
Failure to maintain adequate traceability of the five items
in the standby liquid control and the one item in the drywell
pneumatic systems is considered a violation of 10 CFR 50,
Appendix B, Criterion VIII and the QA Manual, Quality Re-
quirement 3.0 and is an example of an item of noncompliance
(373/81-28-28).
10.
Unresolved Items
Unresolved Items are matters about which more information is required
in order to ascertaic whether they are acceptable Items, items of
Noncompliance, or Deviations. Unresolved Items disclosed during the
inspection are discussed in Paragraph 3.c and 3.d.
11.
Exit Interview
_
The inspectors met with licensee representatives (denoted in Paragraph
1) on September 18, 1981. The inspectars summarized the scope and
findings of the inspection.
The licensee acknowledged the statements by the inspectors with respect
to the items of noncompliance (Paragrapha 3.a
3.b, 3.d, 3.e, 7, 8.a,
and 8.b.).
A meeting was held at the licensee's request on October 8, 1981 to
discuss the containment liner findings (Paragraph 7).
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