IR 05000440/1985042

Insp Rept 50-440/85-42 on 850622-0802.Violations Noted: Failure to Provide Adequate Preoperational Test Procedures & Administrative Controls for Temporary Alterations

ML20134D319
Person / Time
Site:	Perry
Issue date:	08/13/1985
From:	Dave Hills, Lanksbury R, Oduyer G, Odwyer G, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20134D285	List: IR 05000440/1985042 IR 05000622/2008002 ML20134D282
References
50-440-85-42, NUDOCS 8508190184
Download: ML20134D319 (18)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-440/85042(DRS)

Docket No. 50-440 License No. CPPR-148 Licensee: Cleveland Electric Illuminating Company Post Office Box 5000 Cleveland, OH 44101 Facility Name: Perry Nuclear Power Plant, Unit 1 Inspection At: Perry Site, Perry, Ohio Inspection Conducted: June 22 through August 2, 1985 Inspectors: 3MI[

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Test Programs Section Dat'e Inspection Summary-Inspection on June 22 through August 2, 1985 (Report No. 50-440/85042(DRS))

Areas Inspected: Routine, unannounced inspection of previous inspection findings, preoperational test procedure verification, preoperational test procedure review, preoperational test witnessing, preoperational test results verification, preoperational test results review, overall preoperational test program review and preoperational test program implementatio The inspection involved a total of 146 inspector-hours onsite by 3 inspectors including 20 inspector-hours during off-shifts. In addition, there were 121 inspector-hours spent offsit Results: .0f the eight areas inspected, no violations or deviations were identified in six areas. Within the remaining two areas, three violations were identified (Paragraphs 4.a, 4.b, and 4.f - failure to provide adequate preoperational test procedures; Paragraph 9.a - failure to provide adequate administrative controls for temporary alterations; Paragraph 9.b - failure to provide adequate administrative controls for jurisdictional tagging).

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DETAILS 1. Persons Contacted

• D. Lyster, Manager, Perry Plant Operations Department

• F. R. Stead, Manager, Nuclear Engineering Department

• C. M. Shuster, Manager, Nuclear Quality Assurance Department

• G. R. Leidich, General Supervising Engineer, Nuclear Test Section

• H. Gerber, Element Supervisor, Administration, Nuclear Test Section

• J. Tadych, General Supervising Engineer, Operations

• J. Takacs, General Supervising Engineer, Maintenance

• D. Walrath, General Supervising Engineer, Operations Quality Section

• A. Russ, Compliance Engineer, Perry plant Technical Department

• S. Ferrell, Licensing Engineer, Nuclear Engineering Department

• W. Gmyrek, Senior Operations Coordinator, Perry Plant Operations Department

• E. Turosky, Associate Staff Analyst, Perry Plant Technical Department The inspector also interviewed other licensee employees including members of the quality assurance, technical, operating, and testing staf * Denotes persons attending the exit meeting of July 31, 198 . Licensee Action on Previous Inspection Items (Closed) Open Item (440/85017-03(DRS)): Final Safety Analysis Report (FSAR) discrepancies identified during the review of TP IE22-P001, "High Pressure Core Spray (HPCS)." The relief valve described in FSAR Section 6.3.2.2.1 as being located between the two isolation valves of the test line to the condensate storage tank has been replaced by a bypass line and check valve. The inspector verified that a FSAR Change Request has been initiated to correct the discrepancy. In regards to HPCS injection valve IE22-F004 opening time prescribed in FSAR Section 6.3.2.2.1 as 12 seconds following receipt of a signal to open, the actual design requirement is an opening time of 27 seconds following the initiation of a Loss of Coolant Accident (LOCA) signal. The inspector verified that this design requirement had been properly tested in the preoperational test and that an FSAR Change Request has been initiated to correct the discrepanc The inspector has no further concerns in this are (Closed) Noncompliance (440/85013-09(DRS)): Alarm Response Instructions (ARI) for the preoperational test program not being generated and made available to control room operator The inspector verified that Test Program Instruction (TPI)-6 has been revised to ensure consistent implementation with regards to ARIs. This prescribes initiation,

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revision, and' implementation of ARIs.to be in accordance with Perry Plant Operations Department Procedure OAP-050 The inspector has no further concerns in this are .(Closed) Open Item (440/85017-02(DRS)): Responses to Field Questions 046362 and 046363 to be reviewed. The inspector reviewed the identified documents and found them satisfactory. The inspector has no further concerns in this are (Closed) Open Item (440/85029-02(DRS)): Test addendum to be provided to add clarifications to TP-IE21-P001, " Low Pressure Core Spray," test results package. _The inspector reviewed Test Addendum No. 1 and verified that the-identified clarifications had been addressed. The inspector has no further concerns in this are (Closed) Open Item (440/85017-11(DRS)): Licensee management to provide uniform guidance on the implementation'of test exceptions and work authorizations. The inspector verified that procedural requirements for test exceptions and work authorizations have been identified to applicable personnel in the. training program. The inspector has no further concerns in this are .(Closed) Open Item (440/85017-04(DRS)): Licensee management to stress to personnel the importance of keeping the System Test Engineer completely cognizant of activities affecting systems under Nuclear Test Section control. The inspector verified that this item has been stressed to applicable personnel through the training program. The inspector has no further concerns in this are (0 pen) Noncompliance'(440/85013-01(DRS)): Failure to provide adequate preoperational test procedures. The inspector verified that additional examples of this violation, pertaining to TP IE12-P001, " Residual Heat Removal System," Revision 1, as identified in Inspection Report 50-440/85017, have been corrected by incorporation of Test Change Notices 55 and 57 into the test procedure. Additionally, the inspector verified that other examples of this violation pertaining to TP IB33-P002,

" Recirculation Flow Control Valves," Revision 1, that were -identified in the same report have been corrected in Addendum 1 to that procedur However, further examples of this violation have been identified in-Paragraph 4.h of this report for TP IC41A-P001, " Standby Liquid Control System," Revision 0. As a result of concerns over inadequate preoperational test procedures, the licensee formed a Management Procedure Review Team (MPRT) to determine the extent of the problem and to present recommendations for corrective action In implementing the MPRT recommendations, the licensee-has developed Special Project Plan 1102, " Test Procedure Assurance Review." The intent of this plan

. is to ensure preoperational test procedure adequacy by providing an additional review of all preoperational and selected acceptance test procedures, reinforcement of attention to detail to ensure technical

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adequacy of the test procedures, increased supervisory involvement during the evolution and conduct of test procedures and revisions,

-additional training for test personnel, a re-review of licensing commitments, a periodic status of progress, and a final summary of these efforts. The effectiveness of these activities will be further evaluated and tracked by this inspection item. The item remains open pending complete implementation of the above actions and inspector review of their effectivenes (Closed) Open Item (440/85002-05(DRS)): Test personnel appear to rely on General Electric or Gilbert Associates Incorporated test specifications without being totally cognizant of design and testing requirements contained in licensing documents. This item is being addressed by the licensee's Special Project Plan 1102, " Test Procedure Assurance Review," and thus will continue to be tracked by previous inspection item 440/85013-01(DRS).

(Closed) Open Item (440/84-11-11(DRS); 441/84-11-11(DRS)): Complete review of preventative maintenance controls during testing. The inspector reviewed this area as described in Paragraph 8 of this repor (0 pen) Unresolved Item (440/85002-02(DRS)): Consideration of instrument inaccuracies in determination of preoperational test procedure acceptance criteria. The licensee has develeped a Special Project Plan,

" Coordination of Setpoints and Interrelated Documents," which is to address this item in addition to several related issues as described in Paragraph 4.a of this report. Expected completion of this project with a written final report is August 26, 198 (Closed) Open Item (441/84-11-15(DRS)): Review licensee's response to how their program will minimize problems identified in preoperational testing at other facilities. The licensee has provided a written response which the inspector has reviewed and determined to be adequat (Closed) Unresolved Item (440/85013-06(DRS)): Resolve inspector coments/ concerns for preoperational test procedure TP 1C41A-P001, Revision 0, " Standby Liquid Control System." This item has been upgraded to an example of a violation as described in Paragraph 4.h of this report and will be included with the other examples of inadequate procedures identified under violation 440/85013-01(DRS). Therefore, this item

'is considered close (Closed) Open Item (440/84-22-02(DRS)): Licensee to submit and have approved all required FSAR test abstracts. As noted in Paragraph 2.c of Inspection Report 50-440/85017(DRS), the inspector had an open issue with the Office of Nuclear Reactor Regulation (NRR) regarding which test abstracts are required to be included in FSAR Section 14. A response from NRR has been received and it appears no additional action by the

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licensee is required at this time. If additional or modified test abstracts are later found to be necessary NRR will deal directly with the licensee. This item is therefore considered close (Closed) Open Item (440/85013-03(DRS)): Licensee to change the FSAR to upgrade their commitment from ANSI N510-1975 to ANSI N510-1980. The inspector reviewed FSAR Change. Request No. 493 and verified that the licensee was taking appropriate action to resolve this concern and had approved this chang The inspector has no further concerns in this are . Preoperational Test Procedure Verification The inspector verified that the following preoperational test procedures were prepared, reviewed, and approved in accordance with the requirements of Regulatory Guide 1.68, the Test Program Manual (TPM),.the FSAR, the Safety Evaluation Report (SER) and the Quality Assurance (QA) Program and found them satisfactory except as noted below:

TP OG41-P001, " Fuel Pool Cooling and Cleanup System," Revision 2

.TP OM23/24-P001, "MCC Switchgear and Miscellaneous Electrical Equipment Areas HVAC System and Battery Room Exhaust System,"

Revision 2 _

TP OP41-P001, " Cooling Tower Makeup Isolation System," Revision 0 TP OP47-P001, " Control Complex Chilled Water System," Revision 0 TP OP49-P001, " Emergency Service Water Screen Wash System," Revision 2 TP 1C61-P001, " Remote Shutdown System," Revision l'

TP 1F42-P001, " Fuel Transfer Equipment," Revisio TP 1M32-P001, "Emergeacy Service Water Pumphouse Ventilation System,"

Revision 1 TP 1M36-P001, "Off Gas Building Exhaust System," Revision 1 TP 1M43-P001, " Diesel. Generator Building Ventilation System," Revision 2 TP 1P42-P001, " Emergency Closed Cooling System," Revision 2 TP 1R23-P001, "480 Volt Load Centers," Revision 0 TP 1R42-P001, " Class 1E Bus Independence and Division 1 and 2, DC Power System," Revision 0-TP 2R25-P001, "120 VAC Class 1E Instrument and Miscellaneous Distribution Panels," Revision 0-TP 2R42-P002, " Class 1E DC Power Systems Division 3," Revision 0 TP 0G60-A001, " Miscellaneous Sump System, Service Water Valve Pit,"

Revision 0 TP OP41-A001, " Service Water System," Revision 1 TP 1C85-A002, " Steam Bypass and Pressu"e Regulator HPU," Revision 0 TP 1N21-A001, " Condensate System," Revision 0 TP 1N33-A001, " Steam Seal System," Revision 0 TP.1N62-A001, " Condenser Air Removal," Revision 0 TP 1N71-A001, " Circulating Water System," Revision 0 TP IP44-A001, " Turbine Building Closed Cooling System," Revision 2 TP 1P52-A001, " Instrument Air System," Revision 1

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TP 1R52-A001, " Maintenance and Calibration Communications System,"

Revision 0 TP-1N23-A001, " Condensate Filtration System,". Revision 1 TP 2R42-A001, "Non-Class 1E. Power Systems," Revision 0 TP'2R11-A002,:"LH-2-B Interbus Transformer Energization," Revision 0

_TP 1P48-A001,." Service Water Chlorination System," Revision 2 TP 2R11-A001, "LH-2-A Interbus Transformer Energization," Revision 0 TP 1P33-A001, " Turbine Plant Sampling," Revision 0 TP 2S11-A001, "Startup Transformer Energization," Revision 1 TP 2R11-A003, "LH-2-C Interbus Transformer Energization," Revision 1-TP 1P12-A001, " Condensate Seal Water System," Revision 0 TP 1P11-A001, " Condensate Transfer and Storage System," Revision 2 TP 1P51-A001, " Service Air System," Revision 1 TP 1N35-A001, " Hydrogen Supply System," Revision 0 TP 1N34-A001, " Lube Oil Purification," Revision 0-TP 2P52-A001, " Instrument Air System," Revision 0 TP 1N24-A001, " Condensate Demineralizer System," Revision 1 TP 1M49-A001, "HVAC Smoke Venting," Revision 1 TP-1M47-A001, " Steam Tunnel Cooling," Revision 1

'TP 1R11-A002, "LH-1-B Interbus Transformer Energization," Revision 1 TP 1M45-A001, " Circulating Water Pump House Ventilation System,"

Revision 1 TP 1M42-A001, " Turbine Power Complex Ventilation," Revision 2 TP 1M41-A001, " Heater Bay Ventilation," Revision 1 TP 1M35-A001, " Turbine Building Ventilation," Revision 2 TP OP84-A002, "Hypochlorite Generation Cooling Tower Feed and Plant Discharge Dechlorination System," Revision 0

'TP OP34-A001, " Nuclear Sampling System," Revision 0 TP 1P83-A001, " Cooling Tower Acid Addition System," Revision 0 TP OP55-A001, " Building Heating System," Revision 1 TP OP22-A001, " Mixed Bed Demineralizer and Distribution," Revision 0 TP 1R14-A001, "120 VAC Vital-Inverter and Distribution Equipment,"

-Revision 0 ,

TP OP20-A001, " Makeup Water Pretreatment," Revision 0 TP OM48-A001, "Radwaste Control Room HVAC System," Revision 1 TP 1P86-A001, " Nitrogen Supply System," Revision 0 .

TP OM46-A001, " Miscellaneous HVAC Systems," Revision 0 TP OM31-A001, "Radwaste Building Ventilation," Revision 2 TP 1M33-A001, " Intermediate Building Ventilation, " Revision 1 TP 1S11-A001, "Startup Transformer Energization," Revision 1 TP 1R55-A001, " Permanent Plant Telephone System DC Equipment,"

Revision 0 TP 1R42-A001, "Non-Class 1E DC Power Systems," Revision 0 TP OP64-A001, " Plant Industrial Wastes System," Revision 0 '

-TP IL51-A001, " Turbine Room and Circulating Water Pumphouse Overhead Cranes," Revision 2 TP OP21-A001, "Two-Bed Demineralizer and Distribution System,"

Revision 1 l TP 1R11-A003, "LH-1-C Interbus Transformer Energization," Revision 1

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TP 1R11-A001, "LH-1-A Interbus Transformer Energization," Revision 0 TP OP65-A001, " Auxiliary Boiler Chemical Treatment System," Revision 1 TP OP62-A001, " Auxiliary Boiler Fuel Oil System," Revision 0 TP OP40-A001, " Service Water Screen Wash," Revision 1 TP OM37-A001, " Water Treatment Building Ventilation," Revision 0 TP OL51-A003, " Service Water Pumphouse Overhead Crane," Revision 0 No violations or deviations were identifie . Preoperational Test Procedure Review The inspector reviewed the following approved test procedures against .

the FSAR, the SER, Regulatory Guide 1.68, QA Manual, Test Program Manual,

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applicable Regulatory Guides and American National Standards Institute (ANSI) Standards and docketed correspondence and found them satisfactory except as noted below: TP 1C71-P001, " Reactor Protection System," Revision During this review, the inspector noted that the test procedure was not consistent pertaining to the acceptance criteria for Turbine Control Valve Fast Closure Trip Setpoint. Acceptance criteria prescribed a setpoint and tolerance of 530t15 psig while the test step 6.7.1 indicated 530130 psig. The licensee indicated that 530t30 psig was the appropriate setpoint and tolerance and therefore acceptance criteria 7.6 tolerance was incorrect. In addition, the inspector noted that in step 6.7.1.1, the Turbine First Stage Pressure Low Power Setpoint was prescribed as 178.2 psig while in step 6.16.2.2 it was given as 232 psig. The licensee indicated that 178.2 psig was the appropriate setpoint and therefore step 6.16. was incorrect. Also, in step 6.15.1, data sheet 4 prescribed the removal of various fuses to initiate annunciators. However, the test procedure did not provide for restorational replacement of these fuses as required by Test Program Instruction (TPI)-18,

" Temporary Alterations," and TPI-7, "Preoperational Acceptance and Special Test Procedure Preparation Review and Approval." These items are considered an example of a violation in conjucntion with the examples described in Paragraph 4.b and 4.f in that this procedure was inconsistent with administrative requirements and applicable design values (440/85042-01a(DRS)).

In addition, the inspector noted that the procedure prescribes reactor protection system response time testing to be accomplished during the preoperational test in accordance with Initial Checkout and Run-in (IC&R) test procedures. The licensee indicated that these IC&R procedures had not yet been written and approved by the Test Program Review Committee (TPRC) but would be provided for NRC review upon TPRC approval. This is to remain an open item until the licensee has provided these TPRC approved procedures and they have been reviewed by the inspector (440/85042-02(DRS)).

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i The inspector also noted that acceptance criteria 7.1 prescribes a Reactor Vessel. Steam Dome Pressure High trip setpoint as 1064.7 15 psig while Perry " Proof and Review" Technical Specification Table 2.2.1-1 gives a trip setpoint of _1064.7 psig and allowable value of 1079.7 psig. Therefore, the test procedure tolerance allows the trip setpoint to be as high as the technical specification allowable value. This same problem was also identified in respect to the Automatic Depressurization System timer as described in Paragraph 4.e of this repor These tolerances appear to be inconsistent with the proposed Perry specific setpoint methodology which has not yet received approval of NRR. This specific methodology involves establishment of a

" leave-as-is" zone based on setpoints that are determined from the General Electric setpoint methodology. Under this plan, the instrument would not have to be recalibrated until calibration checks have revealed that it has drifted out of this " leave-as-is" zone. The " leave-as-is" zone is to be established in such a manner as to ensure compliance with Regulatory Guide 1.105, " Instrument Setpoints," Revision 1, which states that "setpoints be establishe a with sufficient margin between the technical specification limits for the process variable and the nominal trip setpoints to allow for-(a) the inaccuranc of the instrument, (b) uncertainties in the calibration, and (y)c the instrument drift that could occur during the' interval between calibrations." The examples of test procedure setpoint tolerances given above signify the establishment of this

" leave-as-is" zone as up to and including the technical

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specification allowable value. This clearly conflicts with the proposed Perry specific setpoint methodology. It appears that there has been little consistency or direction provided for the establishment of " leave-as-is" zones. Therefore, if this methodology does receive NRR approval, the possibility exists that extensive effort may be needed to ensure that " leave-as-is" zones have been established correctly and that instruments are recalibrated when discrepancies such as these are discovered. This is considered to be an unresolved item (440/85042-03(DRS)). In order to address this and other related concerns, the licensee has developed Special Project Plan, " Coordination of Setpoints and Interrelated Documents." This plan establishes a review team to investigate various problem areas such as test acceptance criteria versus instrument inaccuracies, the

" leave-as-is" zone, consistent setpoint terminology and definitions, and dynamic interfaces between setpoint design documents. The special project plan is expected to be complete by August 26, 1985, with the issuance of a final report to describe the various problems identified in detail, prescribe an action plan for resolution of any identified problems, and identify the responsible organizations for completion of the action pla >

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. TP 1C71-P002, " Reactor Protection System (RPS) Motor Generator Sets," Revision FSAR Section 8.3.1.1.5.4 indicates that

" provision is made to prevent connection of both RPS buses to the alternate source at the same time." This design feature, consisting of the K2A and K2B relays and corresponding contacts, is to ensure that both RPS buses are not simultaneously supplied from the alternate power source so that these buses are not vulnerable no single failure. The inspector noted that this particular interlock was not tested in the preoperational test procedure. This iten is

' considered an example of a violation in conjunction with the examples described in Paragraphs 4.a and 4.f in that this procedure did not adequately test system design features (440/85042-01b()RS)). TP 1N278-P001, "Feedwater Leakage Control System," Revision TP 1G43-P001, " Suppression Pool Makeup System," Revision TP 18218-P001, " Automatic Depressurization System (ADS / Safety Relief Valves (SRV)," Revision 1. The inspector noted that acceptance criteria 7.1.1 and 7.1.3 prescribes the ADS Timer setpoint as 10512 seconds while Perry " Proof and Review" Technical Specification Table 3.3.3-2 gives a setpoint value of _105 seconds and an allowable value of 117 seconds. Therefore, the test procedure tolerance allows the setpoint to be as high as the technical specification allowable value. This tolerance appears to be inconsistent with the proposed Perry plant specific setpoint methodology utilizing a " leave-as-is" zone as described previously in Paragraph 4.a of this report and thus is considered part of the same unresolved item (440/85042-03(DRS)). TP 1M51-P001, " Combustible Gas Control System (CGCS)," Revision ,

The inspector noted that permanent plant instrumentation used to provide acceptance criteria data in the test procedure were not designated with the symbol "(AC)" on the Instrument Suninary Shee Examples of the numerous discrepancies identified include the sample flow indicators, sample inlet pressure indicators, and sample temperature indicators on hydrogen analyzer panels 1H51-P022A and 1H51-P022B, used to provide data for acceptance criteria 7.1.a and 7.1.b, and the air flow meter on panel 1H51-P174A, used to provide data for acceptance criterion 7.3.a.1. TPI-7, "Preoperational, Acceptance, and Special Test Procedure Review and Approval,"

Section 4.1.2.2 and Attachment 6.5 prescribe the use of the Instrument Summary Sheet. Instructions on the Instrument Suninary Sheet require that the symbol "(AC)" be inserted for all instruments involved with verifying acceptance criteria. This symbol indicates those instruments requiring signature /date verifications to ensure that they have been calibrated within six months of the start of the test and to ensure that they receive post-test calibration verification. This is considered an example of a violation in

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conjunction with the examples described in Paragraphs 4.a and 4.b in that this procedure was inconsistent with administrative requirements (440/85042-01c(DRS)).

In addition, the inspector expressed concern pertaining to CGCS compressor flow rate acceptance criteria as it relates to system design requirements. Present test procedure acceptance criteria prescribes 500150 standard cubic feet per minute (scfm) CGCS compressor capacity under an equalized atmospheric pressure condition between the drywell containment areas and 600160 scfm capacity under equalized but higher pressure conditions during the Containment Integrated Leak Rate Test (ILRT). The licensee has now indicated that they intend to change the acceptance criteria at atmospheric pressure conditions to a minimum of 500 scfm and to include calculations to normalize test data to the design temperature of 60 F for comparison to the acceptance criteri In addition, the licensee intends to delete the testing done under containment ILRT conditions and to instead perform testing as an Initial Checkout end Run-in (IC&R) test at a containment pressure of 22.1 psia during depressurization following completion of the ILRT. This pressure is the postulated containment pressure at which the compressors are started approximately 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> after a Loss of Coolant Accident to ensure that hydrogen concentrations do not exceed the 4.0 percent limits of Regulatory Guide 1.7. The inspector advised the licensee that the plan to do the higher

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pressure test as an IC&R test instead of a preoperational test may

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not be consistent with the intent of Regulatory Guide-1.68s Section C.3, which states in regard to preoperational testing,

"to the extent practical, the plant conditions during the tests should simulate the actual operating and emergency conditions to which the structure, system, on component may be subjected." This is an unresolved item until the inspector has reviewed the planned procedure revision and determined its compliance with regulatory requirements (440/85042-04(DRS)).

The inspector also noted that preoperational testing of the hydrogen recombiners was not as extensive as that required by the 18 month surveillance prescribed by Perry " Proof and Review" Technical Specification Section 4.6.7. The surveillance requires that the recombiner sheath temperature must attain between 1225 F and 1450 F within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and maintain temperature within that range for an additional 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The preoperational test procedure, however, just verifies that the sheath temperature will stabilize at 1225110 F with no specified time periods. The licensee has indicated that the test procedure will be revised to make it consistent with the technical specification surveillance requirements. This is to remain an open item until the inspector

- has reviewed the procedure revision to ensure compatibility with the technical specification surveillance (440/85042-05(DRS)).

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) TP IC418-P001, "St'andby Liquid Control Transfer," Revision TP.1C41A-P001, " Standby Liquid Control System," Revision 0. As

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indicated in Inspection Report 50-440/85013(DRS) (unresolved item

,440/85013-06(DRS)) the inspector had a number of comments / concerns y for this preoperational test procedure that required additional

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inspection effort in order to determine if they were violation .This inspection effort is now complete and unresolved item 440/85013-06 has been upgraded to an example of a violation and is included with the other examples 'of inadequate test procedures

, identified under violation 440/85013-01(DRS). The following is a list of the examples.of violation identified in TP 1C41A-P00 *

The test methodology for verifying the systems restricting orifice flow was inadequate because it did not take into consideration the elevation difference between the location where the static test measurements were performed and the lower level where the orifice flow entered the system primary flow path (pump suction). In addition, consideration of the dynamic effects in place when the system is running were not included. General Electric (GE) and onsite review of this concern,resulted in a new acceptance criterion being generated that took~the above items into consideratio Further review indicated that sufficient data was taken during the conduct of'the test (wnich occurred prior to

resolution.of this concern) to allow it to be used to demonstrate this portion ~of system operation through additional calculations and without any retesting being require * The test methodology used initially to demonstrate that the Standby Liquid Control-(SLC) system storage tank air sparger would perform as' designed was inadequate in that it did not demonstrate that it was capable of mixing the boron solution after the^ maximum time allowed between Technical Specification (TS) surveillances'(*38 days). In addition, it-did not determine how much sparging time is required to ensure that 7' ~

the samples taken for the TS surveillances are representative of the tank contents. The above must be demonstrated since the boron solution will stratify-out over time with a higher -

concentration layer near the bottom and a lower concentration layer near the top (where the TS samples will be taken).

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a minimum flow capacity and boron content equivalent in control capacity to 86 gpm of 13 weight percent sodium pentaborate solution. This equivalent control capacity is for a 251 inch-diameter reactor vesse Since Perry has a smaller size reactor vessel, a different (lower) flow would provide

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equivalent control. A GE analysis in response to this concern resulted in GE.providing the site with an equation whereby compliance with the equivalency requirement can be shown by substituting plant-specific parameters. The original test procedure failed to include consideration of this design requiremen Subsequent review by the licensee has determined that sufficient data had been collected during the original testing.to allow demonstration of the required control equivalency through the use of the above noted GE equatio No additional violations or deviations .were identified. However, 2 open and 2 unresolved items requiring further evaluation as described in the preceding paragraphs were identified in the review of this program are . Preoperational Test Witnessing-The inspector witnessed the following preoperational test to ascertain through. observation and review of documentation that testing was conducted

.in accordance with approved procedures and that test results appeared to be acceptable or proper corrective actions were taken. Additionally, the performance of licensee personnel was evaluated during the test. These were_found to be satisfactor _

SP_1E61-001, " Local Leak Rate Test," Revision The inspector witnessed step 6.5 which consisted of testing per Surveillance Instruction SVI-821-T9122, " Type C Local Leak Rate Test of B21 Penetration P122," Revision 0, to determine the local leakage rate from Main Steam Line C. This testing determined that

'the combined leakage from Inboard Main Steam Isolation Valve (MSIV)

1B21-F022C, Outboard MSIV 1821-F028C, Outboard Before Seat Drain Valve 1821-F067C, MSIV Leakage Control System (LCS)-Inlet Valve 1E32-F001J, and MSIV LCS Drain Valves 1E32-F02J and IE32-F026J was' within acceptance limit No violations or deviations were identified.

j - Preoperational Test Results Verification The inspector verified that the following preoperational test results were documented, reviewed and approved by the licensee in accordance with the requirements of Regulatory Guide 1.68, the TPM, the FSAR, the

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.SER, and the QA Program and found them satisfactor TP OG41-P001, " Fuel Pool Cooling and Cleanup System," Revision 2 TP OM23/24-P001, "MCC Switchgear and Miscellaneous Electrical Equipment Areas HVAC System and Battery Room' Exhaust System,"

Revision 2 TP OP41-P001, " Cooling Tower Makeup -Isolation System," Revision 0

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TP OP47-P001, " Control Complex Chilled Water System," Revision 0 )

TP OP49-P001, " Emergency Service Water Screen Wash System," Revision 2 TP 1C61-P001, " Remote Shutdown System," Revision 1 TP 1F42-P001, " Fuel Transfer Equipment," Revision 1-TP 1M32-P001, " Emergency Service Water Pumphouse Ventilation System,"

Revision 1 TP 1M36-P001, "Off Gas Building Exhaust System," Revision 1 TP 1M43-P001, " Diesel Generator Building Ventilation System," Revision 2 TP IP42-P001, " Emergency Closed Cooling System," Revision 2 TP 1R23-P001, "480 Volt Load Centers," Revision 0 TP 1R42-P001, " Class 1E Bus Independence and Division 1 and 2, DC Power Tystem," Revision 0 TP 2R25-P001, "120 VAC Class lf Instrument and Miscellaneous Distribution Panels," Pe :sion 0 TP 2R42-P002, " Class IE DC Pc,ier Systems Division 3," Revision 0 TP OG60-A001, " Miscellaneous Sump System, Service Water Valve Pit,"

Revision 0 TP OP41-A001, " Service Water System," Revision 1 TP 1C85-A002, " Steam Bypass and Pressure Regulator HPU," Revision 0 -

TP 1N21-A001, " Condensate System," Revision 0 TP 1N33-A001, " Steam Seal System," Revision 0 TP 1N62-A001, " Condenser Air Removal," Revision 0 TP 1N71-A001, " Circulating Water System," Revision 0 TP IP44-A001, " Turbine Building Closed Cooling System," Revision 2 TP IP52-A001, " Instrument Air System," Revision 1 TP 1R52-A001, " Maintenance and Calibration Communications System,"

Revision 0 TP 1N23-A001, " Condensate Filtration System," Rcvision 1 TP 2R42-A001, "Non-Class 1E Power Systems," Revision 0 TP 2R11-A002, "LH-2-B Interbus Transformer Energization," Revision 0 TP 1P48-A001, " Service Water Chlorination System," Revision 2 TP 2R11-A001, "LH-2-A Interbus Transformer Energization," Revision 0 TP 1P33-A001, " Turbine Plant Sampling," Revision 0 TP 2S11-A001, "Startup Transformer Energization," Revision 1 TP 2R11-A003, "LH-2-C Interbus Transformer Energization," Revision 1 TP 1P12-A001, " Condensate Seal Water System," Revision 0 TP 1P11-A001, " Condensate Transfer and Storage System," Revision 2 TP 1P51-A001, " Service Air System," Revision 1 TP 1N35-A001, " Hydrogen Supply System," Revision 0 1 TP 1N34-A001, " Lube Oil Purification," Revision 0 TP 2P52-A001, " Instrument Air System," Revision 0 >

TP 1N24-A001, " Condensate Demineralizer System," Revision 1 TP 1M49-A001, "HVAC Smoke Venting," Revision 1 TP 1M47-A001, " Steam Tunnel Cooling," Revision 1 TP 1R11-A002, "LH-1-B Interbus Transformer Energization," Revision 1 TP 1M45-A001, " Circulating Water Pump House Ventilation System,"

Revision 1 TP 1M42-A001, " Turbine Power Complex Ventilation," Revision 2 TP 1M41-A001, " Heater Bay Ventilation," Revision 1

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TP 1M35-A001, " Turbine Building Ventilation," Revision 2

. TP OP84-A002, "Hypochlorite Generation Cooling Tower Feed and Plant Discharge Dechlorination System," Revision 0 TP OP34-A001, " Nuclear. Sampling System," Revision 0 TP 1P83-A001, " Cooling Tower Acid Addition System," Revision 0-TP OP55-A001, " Building Heating System," Revision 1 TP OP22-A001, " Mixed Bed Demineralizer and Distribution," Revision 0-TP 1R14-A001, "120 VAC Vital-Inverter and Distribution Equipment,"

Revision 0

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TP OP20-A001, " Makeup Water Pretreatment," Revision 0 TP OM48-A001, "Radwaste Control Room HVAC System," Revision 1 TP 1P86-A001, "Nitroge'n Supply System," Revision 0 TP OM46-A001, " Miscellaneous HVAC Systems," Revision 0

TP OM31-A001, "Radwaste Building Ventilation," Revision 2 TP 1M33-A001, " Intermediate Building Ventilation, " Revision 1 TP'1S11-A001, "Startup Transformer Energization," Revision 1 TP 1R55-A001, " Permanent Plant Telephone System DC Equipment,"

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Revision 0 TP 1R42-A001, "Non-Class 1E DC Power Systems," Revision 0

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TP 0P64-A001, " Plant Industrial Wastes System," Revision 0-TP IL51-A001, " Turbine Room and Circulating Water Pumphouse Overhead Cranes," Revision 2 t

TP OP21-A001, "Two-Bed Demineralizer and Distribution System,"

, Revision TP 1R11-A003, "LH-1-C Interbus Transformer Energization," Revision 1

- TP 1R11-A001, "LH-1-A Interbus Transformer Energization," Revision 0

~ TP OP65-A001, " Auxiliary Boiler Chemical Treatment System," Revision 1

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TP OP62-A001, " Auxiliary Boiler Fuel Oil System," Revision 0

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TP OP40-A001, " Service Water Screen Wash," Revision 1 TP OM37-A001, " Water Treatment Building Ventilation," Revision 0 .

TP.OL51-A003, " Service Water Pumphouse Overhead Crane," Revision 0 v

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No violations or deviations were identified.

Preoperational Test Results Review

l The inspector reviewed the results of the following tests against the i FSAR, the SER, Regulatory Guide 1.68, the QA Manual, and the Test Program Manual, and determined that-test changes and test exceptions were processed in accordance with administrative controls, test deficiencies were identified, processed, and corrected as required, results were

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evaluated and met the acceptance criteria, and the results were reviewed and approved as required.

TP 1C41B-P001, " Standby Liquid Control Transfer," Revision No violations or deviations were identified.

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8. Overall Test Program Review The inspector verified that controls for preventative maintenance and equipment protection during and following preoperational testing have been established including:

periodic surveillance as required protection from environmental extremes implementation of periodic maintenance and calibration programs maintenance of cleanliness The inspector also verified that administrative controls have been established which require preparation and retention of maintenance records. During this review, the inspector noted that administrative controls for preventative maintenance were spread throughout several governing documents contributing to confusion as to the applicable controls and could be conducive to program implementation error The inspector also noted that Perry Plant Department Interface 7-1301,

" Maintenance Program Coordination," had not been revised since August 8, 1983, and thus contained references to procedures which no longer exis As a result of these concerns and also since Perry Plant Department Interface 7-1301 was almost redundant with Perry Plant Department Interface 7-1304, " Preventative Maintenance Program," the licensee deleted the former after assuring that any remaining administrative controls had been transferred to the other procedure. Furthermore, the licensee revised Perry Plant Department Interface 7-1304 to reference Test Program-12, " Work Authorizations," instead of the incorrect reference to Project Administration 1107, " Work Authorization Process."

No violations or deviations were identifie . Preoperational Test Program Implementation The licensee's implementation of jurisdictional tagging was reviewed during this inspection period. Test Program Instruction (TPI)-9, Revision 1, Section 4.1.7, provides instruction on how the licensee's jurisdictional tagging program is to be implemented for systems undergoing preoperational testing. This section requires that: for

i electrical equipment, blue jurisdictional tags or stickers be placed

on all electrical components and the associated control switches and breakers; for mechanical equipment, the tags or stickers be placed on all mechanical components such as valves, tanks, pumps, etc.; and for instrument and control equipment, the tags will be placed on all gauges, panels, readily accessible sensing devices, tubing racks, etc. Because of the large amount of instrument and control equipment in the Control Room, the licensee decided to designate everything therein as under Nuclear Test Section (NTS) control and to not individually mark each item. As each instrument or control completed preoperational testing and was turned over to Operations, 15 l

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it was required to be tagged / marked by a green tag / sticker to indicate this status in accordance with Perry Administrative Procedure (PAP) 1401, " Equipment Tagging."

During the review of this area, the inspector found that the Operations personnel had processed a change (Test Change Notice No. 5) to PAP 1401, effective June <1, 1985, which deleted the requirement for green tagging /stickering any systems / components for Unit 1 or Unit 1/2 common required for Unit 1 operation. The justification for this change was that all these systems / components had been turned over from construction to NTS and therefore the previous method of indicating that the system / component was under construction jurisdiction (i.e., no tags / stickers) could now be used by Operations and thereby minimize the amount of paper being processed. The inspector noted that this was a reasonable course of action on the part of the licensee except that NTS's method of identifying jurisdiction in the Control Room had not change Therefore, it was not possible to identify what instrument, controls, electrical equipment, etc., were under NTS jurisdiction and which were under Operations jurisdiction. This is considered to be a violation of 10 CFR 50, Appendix B, Criterion XIV, in that adequate measures to indicate the status of equipment within the Control Room were not established and implemented (440/85042-06(DRS)).

b. The licensee's implementation of control of temporary electrical alterations was also reviewed during this inspection perio TPI-18, Revision 3, provided instructions of how their temporary alteration program was to be implemented. Section 4.1.1 of TPI-18 stated that prior to release for preoperational or acceptance test, it is not necessary that the System Test Engineer (STE) review and approve the implementation and removal of temporary alteration Section 4.1.2 stated that at anytime after system turnover to NTS, the STE may control the implementation and removal of temporary alterations on a system under his jurisdiction by submitting a memorandum to the Test Coordinator which informs him of the effective date of that control. Section 4.1.4 stated that the Test Coordinator shall approve implementation or removal of temporary alterations without the review signature of the STE after the effective date on the memorandum or after connencing preoperational or acceptance testing, whichever occurs firs The ' inspector's review of this revision of the program revealed the following problem. The period of time between a system's release for test authorization and the time that the test commences was not addressed. The release for test package includes, among other things, a walkdown of the system by the STE to verify that the system is per design and a review for any temporary alterations. At this point, baseline data as to the status of the system with respect to temporary alterations is established by the STE. By not requiring the STE to control temporary alterations from this point on renders

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the baseline data suspect since the commencing of actual testing may be months after the release for test authorization. If a temporary alteration is made during this time frame and is still in place when testing is being performed, the results of that testing may not be valid. Section 1.0 of TPI-18 allows temporary alterations to be made and removed without following the requirements therein if it is specifically required by an approved test procedure which contains signature verifications for implementing and returning to norma The Test Coordinator is also required to be notified prior to the alteration and upon its return to normal if the alteration affects a system in operation. It is not clear that just contacting the Test Coordinator instead of the affected STE will ensure that the affected STE's testing is not invalidated by the alteratio In either case, the potential for invalidating test results exists and, depending on how the temporary alteration affects the system operation, this may go undetecte During the course of this inspection and prior to the inspector identifying the above concerns, the licensee issued Revision 4 to TPI-18. This change basically transferred control for implementation of all new temporary alterations to PAP-1402,

" Control of Lifted Leads, Jumpers, Temporary Electrical Devices, and Mechanical Foreign Items." Removal is still controlled by TPI-18. TCN-005 to PAP-1402 was also issued to require the STE's concurrence to any temporary alteration. This programmatic change resolves the inspector's first concern with respect to any temporary alterations processed under PAP-1402. However, the inspector still has concerns with respect to the effect the old program may have had on testing performed under it. In addition, with respect to the second concern noted above, the new PAP-1402 procedure still has the same exception to its requirements as existed in Section 1.0 of TPI-18 except that it does not even require the Test Coordinator be notified of the implementation or removal of any temporary al teration The failure of the Perry test program to address the above noted problem areas is considered to be a violation of 10 CFR 50,

Appendix B, Criterion XI, and Criterion XIV in that adequate measures were not established to insure that the STE was aware of the status of his system while it is undergoing testing and to thoroughly ensure that the required testing demonstrated that the structures, systems, and components will perform satisfactorily

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inservice (440/85042-07(DRS)).

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10. . Unresolved Items Unresolved items are matters about which information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items disclosed during the inspection are discussed in Paragraphs 4.a, 4.e, and . Open Items Open items are matter which have been discussed with the licensee which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 4.a and . Exit Interview The inspector met with licensee representatives denoted in Paragraph 1 on July 31, 1985. The inspector summarized the scope and findings of the inspection and discussed the likely content of this inspection repor The licensee did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur The licensee acknowledged the statements by the inspector with respect to the violations in Paragraphs 4.a, 4.b, 4.f, 9.a, and