ML20033A452

From kanterella
Jump to navigation Jump to search
IE Insp Rept 50-322/81-13 on 810811-14.Noncompliance Noted: Failure to Maintain Document Control Re Update of Startup Manual 43
ML20033A452
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 10/05/1981
From: Bettenhausen L, Pullani S, Rekito W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20033A446 List:
References
50-322-81-13, NUDOCS 8111250443
Download: ML20033A452 (10)


See also: IR 05000322/1981013

Text

.

-

.

.

U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

Region I

~

Report No. 50-322/81_13

Docket No. 50-322

License No. CPPR-95

' Priority

Category

B

--

L'censee:

Long Island Lighting Company

175 East Old Country Road

Hicksville, New York 11801-

Facility NaLe:

Shoreham Nuclear Power Station

Inspection At:

Shoreham, New York

Inspection Conducted:

August 1 -14,

98

/8h/D

,

Inspectors:

W. A. Rekito, Reactor Inspector

date / signed

hk

w&

l0S/~9'l

5.V. Pullani, Reactor Inspector

date signed

Approved By:

M

b

MM/V

L.H. Bettenhausen, Chief, Test Programs

date signed

Section, Engineering Inspection Branch

Inspection Summary:

Inspection on August 11-14, 1981 (Report No. 50-322/81-13)

Areas Inspected: Routine, unannounced inspection of the preoperational test

program impler.entation including review of program status, control of test

equipment, document control, equipment protection and cleanliness control,

I

test procedure review, and test witnessing; tours of the facility; and

followup on previous inspection findings. The inspection involved 38

inspector-hours onsite by two region based NRC inspectors.

Results: One item of noncompliance was identified in one area.

(Failure to

maintain document control-Paragraph 3.d)

Region I Form 12

-

(Rev. April 77)

,

M Oh

2

(

k rDR

. _ - .

_-

,

_

_

,

_

__

_

__.

_ . .

.

_

_

. -

-d

.

.

Ic

Persons Contacted

Long Island Lighting Company (LILCO)

.

  • T. Gerecke, QA Manager

W. Klein, Lead Startup Engineer

  • A. Muller, QC Engineer-0QA
  • W. Steiger, Chief Operating Enginear

D. Terry, Assistant Startup Manager

  • E. Youngling, Startup Manager

.

General Electric (GE)

M. Daus, Senior Test Engineer

K. Nichulus. Senior Test Engineer

P. Quinn, Test Engineer

J. Riley, Lead Startup Engineer

Stone & Webster (S&W)

  • W. Matejek, Lead Advisory Engineer

U.S. Nuclear Regulatory Commission

  • J. Higgins, Senior Resident Inspector

The inspector also talked with and interviewed other licensee and

contractor employees during the course of the inspection including

operating, maintenance, testing, clerical, and construction personnel.

!

  • denotes those present at the exit interview.

l

'

2.

Licensee Action on Previous Inspection Findings

j

(Closed) Unresolved Item (322/81-07-02): Cleaning of Main Steam

safety / relief valve discharge lines. The licensee voided exception

l

  1. 5 to procedure CF.109.001 and issued TCN #3 which was a special

l

flush procedure for each of the eleven subject lines. This TCN

l

included a visual inspection of the T-Quencher interior surfaces to

verify class C cleanness criteria. The inspector reviewed the

documentation and noted that 0QA had witnessed the visual inspections

,

and that the Lead Startup Engineer and OQA had approved the test

results. This item is considered closed.

!

l

ll

-v

i

ye

.

.

3

3.

Preoperational Test Program Implementation

=

a.

Test Program Status

The inspector met with startup department staff members and

.

held discussions on the following items and subjects:

System turnovers and delays;

--

Test procedure status;

--

Test completion status and delays;

--

Test sequencing and schedules.

--

In addition, the inspector reviewed the latest detailed Preoperational

Test Schedules dated June 1,1980 and noted a revised date for

fuel loading to be September 20, 1982.

No discrepancies or unacceptable conditions were identified

during this review.

b.

Test and Measurement Equipment

The inspector interviewed technicians and reviewed records to

verify that administrative controls established in Startup

Instruction No. 3 and procedure SP 41.003.01,_ Control of I&C

Measuring and Test Equipment, were being implemented.

For this review the inspector selected four pieces of test and

measuring equipment, observed being used by test personnel,

and verified the following:

Identification tags were attached;

--

Calibration stickers were attached and were within required

--

calibration due date;

Instruments were listed on technicians M&TE Usage Card;

--

Completed tests were properly recorded on the M&TE Custody

--

Control Record;

Instrument calibration records were complete and in

--

conformance with respective calibration procedures.

As a result of these observations, record reviews, and interviews,

no discrepancies were identified by the inspector.

.-

.

_

_

. _

,

-

.

.

4

c.

Equipment Protection and Cleanliness

The inspector interviewed test' engineers and reviewed the.

~

,

following instructions to ascertain that administrative controls

are established and implemented to protect the cleanliness of

eq'uipment'and piping systems which have been cleaned / flushed.

Startup Manual Section 4.4.4, Maintenance of Cleanliness.

--

Startup Instruction No.

5,' Revision 0, " Maintaining

--

Cleanliness During Repair / Rework of Flushed Systems."

Startup Instruction No. 1, Rev'ision 5, " Preparation of

--

Interim Operating Instructions."

Interim Operating Instruction for Subsystem E 41, High

--

Pressure Coolant Injection, dated 7/27/81.

In addition, the inspector observed'special equipment protection

measures taken and system cleanliness controls _during general

plant tours and while witnessing the Core Spray Pump Operations.

As a result of these reviews and observations, no unacceptable

conditions were identified,

d.

Document Control

On August 13, the inspector was using the Startup Manual

located in the control room and discovered that the Manual did

not contain the latest revision of Startup Instruction No. 1.

Further review of this Startu,$ Manual No. 43 revealed that it

was not up-to-date. The inspector identified the following

specific problems to the licensee:

Revision No 12, dated 2/18/81 was not incorporated into

--

the manual.

The manual was missing Startup Instruction No. 8, Revision-

--

0, dated 2/3/81, " Rework of General Electric Co. Type SB-

1 Control Switches."

,

The manual contained Startup Instruction No. 1,-Preparation

--

of Interim Operating Instructions,-Revision 4, dated

7/28/80 instead of the latest Revision 5, dated 5/27/81.

.

The manual contained Startup Instruction No. 6, Disassembly / Reassembly

--

'

of ASME XI Bolted Joints, Revision 0, dated 10/20/80

instead of Revision 1, dated 3/3/81.

.

.

-

.

.

5

The manual contained Startup Instruction No. 7, Establishing

--

Periodic Recalibration of Instruments and Relays that

have initial C&IO completed, Revision 0, dated 11/11/80,

,

instead of Revision 1, dated 6/29/81.

'

The licensee promptly corrected this problem by retrieving and

epdating the subject Startup Manual. The licensee representative

explained to the inspector that this manual was not updated

since January, 1981, when the distribution clerk mistakenly

assumed it to be lost and considered it " VOID". However, no

record of this disposition was available and the " Controlled"

Manuals Distribution List dated 2/18/81 incorrectly assigned

Startup Manual Copy No. 43 to a different recipient.

On August 14, the inspector verified that Startup Manual Copy

No. 43 was up-to-date and that the official distribution

records were corrected.

In addition, three other " Controlled"

Startup Manual Copies were audited and found to be up-to-date.

The Operational Quality Assurance Supervisor identified the

last audit of the Startup Manual Document Control to be Audit

Report No. 79-08, dated 8/14-23/79 with satisfactory findings.

However, due to the above finding he stated that a thorough

audit of the Startup Manual Document Control Program would be

conducted by 0QA.

The inspector stated to the licensee that failure to maintain

control of the Startup Manual Copy No. 43 as described above,

does not meet the requirements stated below and is considered

an item of noncompliance (322/81-13-01).

10 CFR 50, Appendix B, Criterion VI requires that measures

--

be established to control the issuance of documents.

FSAR Section 17.2.6 requires that LILCo organizations

--

establish a document control system with measures to

assure the prompt, distribution of approved revisions

including control of obsolete or superseded documents to

prevent their inadvertent use. The QA department is also

required to assure overall program adequacy and implementation.

LILCodperationalQualityAssuranceManualSection6

--

.

requires that managers of organizations establish procedures

which assure the prompt distribution of all approved

changes and revisions including provisions for retrieval

or destruction of superseded documents to prevent their

inadvertent use.

Startup Manual Section 1.3 identifies the Startup Manual ~

-

--

-as a controlled document and requires that its distribution

be maintained definite.

. . -

.

. .

_... _ ._,._. _._. __., ._. _

_

. _ _

. . _ _

.

,

. - .

.

.

-

.

6

4.

Test Procedure Verification

The following procedures were reviewed to verify that adequate

=

testing is planned to satisfy regulatory guidance and licensee

commitments for the Preoperational Testing Program:

,

CF 120.001-1, Revision 0, Recirc MG Set Lube Oil System Flush.

--

CF 108.002-A-1, Revision 0, Emergency Diesel Generator 101

--

Jacket Water Flush.

CF 108.002-B-1, Revision 0, Emergency Diesel Generator 102

--

Jacket Water Flush.

CS 604.001-1, Revision 0, Local / Average Power Range Neutron

--

Monitoring System.

CF 707.001-1, Revision 0, Fuel Pool Cooling and Cleanup Flush.

--

CS 703.001, Revision 0, Fuel Handling and Vessel Service

--

Equipment Test.

CS 611.001-1, Revision 0, Reactor Protection System Specific

--

C&IO.

CF 718.001, Revision 0, Liquid Radwaste spent Resin System

--

Flush (I).

CF 116.001-1, Revision 0, MSIV Leakage Control System.

--

CF 121.001-1, Revision 0, RHR System Flush.

--

CS 307.004 A, B, C, Revision 0, Emergency Diesel 101 Pneumatic

--

Control Board.

CF 709.001-1, Revision 0, Reactor Water Cleanup System.

--

CF 203.001-2, Revision 0, Core Spray System.

--

CF 202.002-1, Revision 0, High Pressure Coolant Injection

--

System.

CF 119.002-1, Revision 0, RCIC System Flush.

--

CF 307.002 C, Revision 0, Emergency Diesel Generator Air Start

--

Flush.

AT 000.002 Revision 0, Station Grounding.

--

.. ._

_

_

_ - - _ .

_ .__

__.

_._

.

_

.

.

-

.

.

7

AT 192.001-2, Revision 0, Screenwash and Traveling Screens.

--

AT 102.001-1,- Revision 0, Vacuum Priming System.

"

--

AT 308.001 A, Revision 0, 4,160 Normal Bus 1A Distribution.

--

-

AT 715.002, Revision 0, Turbine Building Sample, P 33 B.

--

PT 712.001, Revision 0, Regenerative Evaporator System.

--

PT 410.001 A-3, Revision 0, Battery Room Ventilation System.

--

PT 718.001, Revision 0, Liquid Radwaste Spent Resin System.

--

PT 414.001 A-2, Revision 0, Diesel Generator Room Ventilation

--

Syste.1

PT 410.001 B-3, Revision 0, Battery Room Ventilation System.

--

PT 410.001 C-3, Revision 0, Battery Room Ventilation System.

--

PT 307.003B, Revision 0, Emergency Diesel Generators.

--

PT 136.003, Revision 0, Automatic Depressurization System.

--

PT 309.001B, Revision 0, 4,160 V Power Distribution.

--

PT 609.001, Revision 0, Rod Ses

ce Control System.

--

PT 110.001, Revision 0, MSIV Le.

Control Preoperational

--

Test.

PT 129.001, Revision 0, Turbine

're Control.

--

,.

The inspector verified that the test procedu

,above were reviewed

.

and approved in accordance with established administrative procedures

and that test objectives were consistent with regulatory guidance

and licensee commitments for the Preoperational Testing Program.

No discrepancies were noted in the review of these procedures.

5.

Test Procedure Review

The inspector reviewed the following for technical and administrative

adequacy: .(1) Emergency Diesel Generator 101 Electrical Preoperational

Test Procedure PT 307.003A, approved by the Joint Test Group (JTG)

on July 17, 1981, and (2) the 4160 Volt Power Distribution Preoperational

Test Procedure PT 309.001B, approved by JTG on October 22, 1980.

In addition to the standard procedure content requirements listed

below, the procedure detail was examined to insure that design

.

__

,

-

.

.

8

requirements and important system performance functions, as described

in applicable sections of the FSAR and Regulatory Guides are being

demonstrated adequate 1ly.

Management review and approval;

--

,

.

Procedure format;

--

Test objectives clearly stated;

--

Prerequisites;

--

Environmental conditions;

^

--

Acceptance criteria;-

--

References;

--

Initial conditions;

--

Test objectives are met;

--

Performance verification;

--

Recording conduct of test;

--

Restoration of systems to normal after test;

--

Independent verification of critical steps or parameters.

--

Based on the above review the inspector identified the following

concerns for possible procedure inadequacies and discussed them

with appropriate licensee personnel.

a.

The test procedures (PT 307.003A and PT 309.0019) did not

include the diesel generator reliability demonstration tests

(23 consecutive valid tests per diesel) as required by regulatory

position C.2.a(9) of Regulatory Guide 1.108 (Revision 1 August,

1977), the compliance of which is a licensee commitment in the

licensee response to NRC request 423.1 in FSAR. However, the

responsible licensee test personnel assured the inspector that

the above test will be included in another test procedure (PT

307.004A Emergency Diesel Generator 101 Reliability Qualifications)

which is planned to be written.

,

b.

The test procedures (PT 307.003A and PT 309.001B) did not

.

include tests in which redundant diesel generator units are

started simultaneously to help identify certain common failure

modes undetected in single diesel. generator unit tests. This

is required by regulatory position C.2.b of RG 1.108 to which

,

~ = --

_

_

_

- .

,

,

_

_.

_ _

.

'

.

,

9

g

the~1icensee is committed (see response.to NRC request 423.1

in FSAR). The licensee test personnel assured the inspector

that the above test will be included in another test' procedure.

"

(PT 307. & Electrical System Integrated Preoperational Test)

which is planned to be written.

.

!

-

c.

The procedures (PT 307.003A and PT 309.001B) did not include

tests to demonstrate proper operation for design-accident-

loading-sequence, as required by ' regulatory position C.2.a(2)

-of RG 1.108 to which the licensee.is committed. However,

.

Paragraph 1.7~of PT 307.003A stated that this test will be

i

conducted as part of PT 307.002 Electrical System Integrated

Preoperational Test, which is planned to be written. This was.

.

confirmed by the licensee test personnel.

,

The inspector verified from the latest Startup Procedure Status

!

Listing (issued August 7, 1981) that the additional test procedures-

(PT 307.004A and PT 307.002) required to fully satisfy the licensee

,

commitments relating to regulatory positions C.2.a and C.2.b of RG 1.108 are in fact planned to be written.

The inspectors' . concerns for procedure adequacy were satisfied and .

the inspector had no further questions in this area.

6.

Station Operating Surveillance Procedures

.rj'

The following " Draft" inservice surveillance testing procedures

were received for review:

!

i

SP 24.116.02, Revision B, Main and Auxiliary Steam Valve

--

Operability Test.

I

SP 24.119.04, Revision B, RCIC System Valve Operability Test.

i

--

SP 24.121.01, Revision C,-LPCI/ Suppression Pool Cooling Piping

--

Vented, Pump Operability and Flow Rate Test, RHR Pumps ASME XI

Inservice Inspection.

4

SP 24.123.04, Revision C, Standby Liquid Control. System Valve

--

Operability Test.

!

SP 24.203.02, Revision OA, Core Spray Valve Operability Test.

i

--

These procedures were not reviewed during the inspection period.'

However, the inspector stated that they would be reviewed as a

sampling of the planned inservice testing program implementation.

,

The review will ascertain conformance with technical and administrative

requirements contained in Subsections IWP and IWV, Inservice Testing

of Pumps and Valves in Nuclear Power Plants, of Section XI,;ASME

. Boiler and Pressure Vessel. Code.

i

'

- . . _ . .

m-

N'

.

.

10

The inspector stated that the results of this review would be

provided during a subsequent inspection.

72

Test Witnessing

On August 12, 1981, the inspector observed preparations for and

.

operation of the Core Spray Pump A in accordance with generic C&IO

Test Procedure CG.000.001-5, Rotating Equipment. The purpose of

this_ testing was to satisfy the minimum "run-in" time requirements

and to perform a complete pump vibration analysis with a vendor

representative present. As part of his observations, the inspector

verified that:

.

Test procedure in use was properly approved and the latest

--

revision;

--

Reference drawings in use were the latest revisions;

--

Test personnel were suitably qualified and knowledgeable of

the procedure requirements;

--

Test equipment was properly installed, calibrated, and in use.

No discrepancies or unacceptable conditions associated with the

test activity were identified by the inspector.

8.

Plant Tour

The inspector made several tours of the facility, including the

reactor building, control room and turbine building.

During these tours, the inspector observed and evaluated work in

progress, general equipment protection and cleanliness controls,

component tagging for safety and jurisdictional purposes, and

operation of equipment in the Core Spray System.

No unacceptable conditions were found.

9.

Exit Interview

l

The inspector met with licensee management representatives (see

Detail 1 for attendees) at the conclusion of the inspection on

August 14, 1981.

The inspector summarized the scope and findings

of the inspection at that time.

J

-%,

..*m..